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 - delay in filing appeal - The assessee, has therefore, not been vigilant in challenging the re-assessment proceedings as well as the penalty proceedings. The assessee’s explanation is common for all the appeals proceedings. - Condonation of delay not allowed - AT
Condonation of delay - delay in filing appeal - The assessee, has therefore, not been vigilant in challenging the re-assessment proceedings as well as the penalty proceedings. The assessee’s explanation is common for all the appeals proceedings. - Condonation of delay not allowed - AT
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