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...
Section 37A could be invoked on a continuing contravention that extended beyond its insertion, and the appeal was maintainable by the Union of India as an aggrieved person through an authorised officer. The Tribunal held that false answers in ODI filings could not be excused by later form changes, and that protective seizure under Section 37A was wrongly set aside on that basis. It also found the Competent Authority's acceptance of step-down subsidiary reporting compliance and bona fide use of ODI funds to be perverse for want of supporting material. Alleged denial of natural justice was rejected because the respondent had received summons, filed replies, and obtained further time. The impugned order was set aside and the seizure restored.
Section 37A could be invoked on a continuing contravention that extended beyond its insertion, and the appeal was maintainable by the Union of India as an aggrieved person through an authorised officer. The Tribunal held that false answers in ODI filings could not be excused by later form changes, and that protective seizure under Section 37A was wrongly set aside on that basis. It also found the Competent Authority's acceptance of step-down subsidiary reporting compliance and bona fide use of ODI funds to be perverse for want of supporting material. Alleged denial of natural justice was rejected because the respondent had received summons, filed replies, and obtained further time. The impugned order was set aside and the seizure restored.
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