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...
Reconciliation statement dispute regarding an extended period of limitation under section 74 was not addressed by the adjudicating authority, which recorded perfunctory observations; the authority is directed to re-examine the limitation contention and the assertion of having supplied the reconciliation statement and to afford the petitioner an opportunity of hearing before passing a fresh order. The adjudicating authority must deal substantively with the limitation issue and factual assertions and issue a reconsidered order within twelve weeks from receipt of the direction.
Reconciliation statement dispute regarding an extended period of limitation under section 74 was not addressed by the adjudicating authority, which recorded perfunctory observations; the authority is directed to re-examine the limitation contention and the assertion of having supplied the reconciliation statement and to afford the petitioner an opportunity of hearing before passing a fresh order. The adjudicating authority must deal substantively with the limitation issue and factual assertions and issue a reconsidered order within twelve weeks from receipt of the direction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
