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...
Waiver under Section 244 for a company limited by guarantee was considered on the basis of prima facie oppression and mismanagement, exceptional circumstances, and alleged violation of the Articles of Association. The Appellate Tribunal accepted that at the waiver stage a detailed merits review was unnecessary and that concise reasons were sufficient if relevant factors were considered. It found that the order had addressed the club's affairs, the alleged illegal termination and suspension of a member during pending proceedings, the convening of the EOGM, and broader mismanagement allegations. The challenge was treated as affecting members' rights and club governance, and the withdrawal of 49 members did not defeat waiver at that stage.
Waiver under Section 244 for a company limited by guarantee was considered on the basis of prima facie oppression and mismanagement, exceptional circumstances, and alleged violation of the Articles of Association. The Appellate Tribunal accepted that at the waiver stage a detailed merits review was unnecessary and that concise reasons were sufficient if relevant factors were considered. It found that the order had addressed the club's affairs, the alleged illegal termination and suspension of a member during pending proceedings, the convening of the EOGM, and broader mismanagement allegations. The challenge was treated as affecting members' rights and club governance, and the withdrawal of 49 members did not defeat waiver at that stage.
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