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...
Condonation of delay in filing an appeal - the assessee was assisted by a team of experts/taxation heads/qualified persons, therefore, we find no merit in the claim of the assessee for condoning the delay. - AT
Condonation of delay in filing an appeal - the assessee was assisted by a team of experts/taxation heads/qualified persons, therefore, we find no merit in the claim of the assessee for condoning the delay. - AT
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