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...
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
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