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...
Power of Tribunal to dismiss the Appeals for want of prosecution - Even if the assessee could not appear, the Tribunal should decided the appeal on merits, ex parte, after hearing the Revenue Side - dismissal of the appeal for want of prosecution is not only illegal but also entails further litigation - Tribunals should not shirk their responsibility to decide the cases on merits
Power of Tribunal to dismiss the Appeals for want of prosecution - Even if the assessee could not appear, the Tribunal should decided the appeal on merits, ex parte, after hearing the Revenue Side - dismissal of the appeal for want of prosecution is not only illegal but also entails further litigation - Tribunals should not shirk their responsibility to decide the cases on merits
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