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 of 362 days - the main cause of delay was difference of opinion between the two Officers and ultimately legal opinion was taken and it was decided to file the appeal - delay condoned.
Condonation of delay - delay of 362 days - the main cause of delay was difference of opinion between the two Officers and ultimately legal opinion was taken and it was decided to file the appeal - delay condoned.
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