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...
Curative petitions were found defective because the registry-communicated defects had not been cured, and the Court nevertheless examined the matter on merits. Applying the parameters laid down in Rupa Ashok Hurra, it held that no case was made out to entertain the petitions, and the request for listing in open court was rejected. The petitions were therefore dismissed, with the Court indicating that the extraordinary curative jurisdiction was not available on the facts presented.
Curative petitions were found defective because the registry-communicated defects had not been cured, and the Court nevertheless examined the matter on merits. Applying the parameters laid down in Rupa Ashok Hurra, it held that no case was made out to entertain the petitions, and the request for listing in open court was rejected. The petitions were therefore dismissed, with the Court indicating that the extraordinary curative jurisdiction was not available on the facts presented.
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