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...
HC held that the appeal had been rejected on limitation, though partial tax liability was admitted. Total tax demand was Rs. 9,99,558/-, of which the petitioner had accepted Rs. 3,65,918/- but deposited only Rs. 99,956/-. HC directed the petitioner to deposit the balance admitted tax of Rs. 2,65,962/- within 30 days, and additionally to deposit Rs. 1,58,410/-, being 25% of the disputed tax of Rs. 6,33,640/-, from the petitioner's Electronic Cash Register within the same period. On such compliance, the 1st respondent/Appellate Authority was mandated to entertain the appeal and decide it on merits, without rejecting it on the ground of limitation. The petition was disposed of with these directions.
HC held that the appeal had been rejected on limitation, though partial tax liability was admitted. Total tax demand was Rs. 9,99,558/-, of which the petitioner had accepted Rs. 3,65,918/- but deposited only Rs. 99,956/-. HC directed the petitioner to deposit the balance admitted tax of Rs. 2,65,962/- within 30 days, and additionally to deposit Rs. 1,58,410/-, being 25% of the disputed tax of Rs. 6,33,640/-, from the petitioner's Electronic Cash Register within the same period. On such compliance, the 1st respondent/Appellate Authority was mandated to entertain the appeal and decide it on merits, without rejecting it on the ground of limitation. The petition was disposed of with these directions.
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