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...
Validity of notifications issued under the impugned scheme was challenged on grounds that portal uploading under 'Additional Notices and Orders' did not constitute proper service and that non-compliance with statutory procedural requirements vitally affected the order's validity; the writ was entertained on those vires and natural justice grounds, and an interim restraint was granted on recovery while the attachment imposed by tax authorities is ordered lifted pending disposal of the petition.
Validity of notifications issued under the impugned scheme was challenged on grounds that portal uploading under 'Additional Notices and Orders' did not constitute proper service and that non-compliance with statutory procedural requirements vitally affected the order's validity; the writ was entertained on those vires and natural justice grounds, and an interim restraint was granted on recovery while the attachment imposed by tax authorities is ordered lifted pending disposal of the petition.
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