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 of appeal - delay of 3 years - Notice of demand u/s 156 - assessee could not demonstrate that, it was prevented by sufficient cause, in filing this appeal within the time stipulated under the Act. - AT
Condonation of delay in filing of appeal - delay of 3 years - Notice of demand u/s 156 - assessee could not demonstrate that, it was prevented by sufficient cause, in filing this appeal within the time stipulated under the Act. - AT
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