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 of 439 days - sufficient cause - lack of proper advice - appeal filed against assessment order before the CIT (A) within time but no Challenge of order of CIT passed u/s 263 - it was not a total lack of diligence on the part of the assessee - The sufficiency of the cause shown by the appellant is a matter to be weighed on the scales of justice
Condonation of delay of 439 days - sufficient cause - lack of proper advice - appeal filed against assessment order before the CIT (A) within time but no Challenge of order of CIT passed u/s 263 - it was not a total lack of diligence on the part of the assessee - The sufficiency of the cause shown by the appellant is a matter to be weighed on the scales of justice
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