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...
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
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