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...
Rejection of a refund claim was challenged on the ground that necessary supporting documents had not been furnished earlier and a further opportunity was sought to produce additional documents. Applying a justice-oriented approach and principles of fair opportunity, the impugned orders rejecting the refund were set aside and the matter was remitted to the adjudicating authority for fresh reconsideration in accordance with law after granting one more opportunity to file the requisite documents; the petition was allowed by way of remand. - HC
Rejection of a refund claim was challenged on the ground that necessary supporting documents had not been furnished earlier and a further opportunity was sought to produce additional documents. Applying a justice-oriented approach and principles of fair opportunity, the impugned orders rejecting the refund were set aside and the matter was remitted to the adjudicating authority for fresh reconsideration in accordance with law after granting one more opportunity to file the requisite documents; the petition was allowed by way of remand. - HC
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