Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The HC dismissed the writ petitions subject to conditions: the Appellate Authority's initial rejection of an appeal for failure to make the mandatory pre-deposit was upheld as valid, and a subsequent belated appeal was held time-barred; res judicata did not apply because the first appeal was not an appeal in law. The petitions are disposed by directing restoration of the appeal before the Appellate Authority provided the petitioner deposits 25% of the disputed tax in cash from the petitioner's Electronic Cash Register within 30 days of receipt of the order, failing which the Appellate Authority may proceed in accordance with law.
The HC dismissed the writ petitions subject to conditions: the Appellate Authority's initial rejection of an appeal for failure to make the mandatory pre-deposit was upheld as valid, and a subsequent belated appeal was held time-barred; res judicata did not apply because the first appeal was not an appeal in law. The petitions are disposed by directing restoration of the appeal before the Appellate Authority provided the petitioner deposits 25% of the disputed tax in cash from the petitioner's Electronic Cash Register within 30 days of receipt of the order, failing which the Appellate Authority may proceed in accordance with law.
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