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 - No doubt the explanation offered is not convincing but there is nothing on record brought by the Revenue to show that the appellant had purposely and willfully delayed in filing the appeal within the period of limitation - Delay condoned.
Condonation of delay - No doubt the explanation offered is not convincing but there is nothing on record brought by the Revenue to show that the appellant had purposely and willfully delayed in filing the appeal within the period of limitation - Delay condoned.
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