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...
Maintainability of appeal before CIT(A) - First appeal was filed manually - dismissed in limine - again filed appeal electronically with Condonation of delay - delay condoned - second appeal is maintainable & The assessee has taken right step in moving fresh appeal before CIT(A) through electronic mode.
Maintainability of appeal before CIT(A) - First appeal was filed manually - dismissed in limine - again filed appeal electronically with Condonation of delay - delay condoned - second appeal is maintainable & The assessee has taken right step in moving fresh appeal before CIT(A) through electronic mode.
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