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...
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - priority for disposal of appeals in different Categories - there is neither firm directives that certain class or kinds of Appeals must be decided before a particular date, nor there is any negative implication of a particular CIT(A) not being able to do so - guidelines are directory and not mandatory.
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - priority for disposal of appeals in different Categories - there is neither firm directives that certain class or kinds of Appeals must be decided before a particular date, nor there is any negative implication of a particular CIT(A) not being able to do so - guidelines are directory and not mandatory.
Note: It is a system-generated summary and is for quick reference only.
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