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...
Recall of an order passed on merits was held impermissible where the appellant had participated through counsel, advanced submissions, and was effectively on notice; the plea of non-impleadment, absence of notice and denial of hearing was rejected because no apparent procedural flaw attributable to the Tribunal was shown. The Tribunal held that recall cannot be used to reopen a merits-based order after hearing. The separate appeal against the original order was also held time-barred under the IBC, and exclusion of time under Section 14 of the Limitation Act was denied because the recall and writ proceedings could not be used to bypass the statutory appeal period. The delay condonation plea was rejected.
Recall of an order passed on merits was held impermissible where the appellant had participated through counsel, advanced submissions, and was effectively on notice; the plea of non-impleadment, absence of notice and denial of hearing was rejected because no apparent procedural flaw attributable to the Tribunal was shown. The Tribunal held that recall cannot be used to reopen a merits-based order after hearing. The separate appeal against the original order was also held time-barred under the IBC, and exclusion of time under Section 14 of the Limitation Act was denied because the recall and writ proceedings could not be used to bypass the statutory appeal period. The delay condonation plea was rejected.
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