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 - against two order for penalty U/s. 271AAA and u/s 271(l)(c) joint one appeal was filed - subsequently after decision of CIT(A) separate appeal was filed - no undue advantage has been derived by the assessee by filing the appeal late and no vested right of the Revenue can be said to have been disturbed in case the delay is condoned - the mistake at best can be said to be a technical mistake which stands corrected
Condonation of delay - against two order for penalty U/s. 271AAA and u/s 271(l)(c) joint one appeal was filed - subsequently after decision of CIT(A) separate appeal was filed - no undue advantage has been derived by the assessee by filing the appeal late and no vested right of the Revenue can be said to have been disturbed in case the delay is condoned - the mistake at best can be said to be a technical mistake which stands corrected
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