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 the facts ofthe assessee’s case, we condone the delay of 72 days in filing of appeal before the CIT(A) and direct the Ld. CIT(A) to decide the issue on merits. - AT
Condonation of delay - In the facts ofthe assessee’s case, we condone the delay of 72 days in filing of appeal before the CIT(A) and direct the Ld. CIT(A) to decide the issue on merits. - AT
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