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...
Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
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