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...
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
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