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 the IT return - powers u/s 119 - when the explanation offered was acceptable and genuine hardship is established. It was with a fond hope of getting justice at the hands of the CCIT - no decision was taken for nearly 6 years - Finally the said petition has been dismissed which has to be viewed seriously while rendering substantial justice to the parties. - Matter restored before CCIT. - HC
Condonation of delay in filing the IT return - powers u/s 119 - when the explanation offered was acceptable and genuine hardship is established. It was with a fond hope of getting justice at the hands of the CCIT - no decision was taken for nearly 6 years - Finally the said petition has been dismissed which has to be viewed seriously while rendering substantial justice to the parties. - Matter restored before CCIT. - HC
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