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 - revision u/s 264 - as the order u/s 143(1) came to be passed within this one year itself, writ petitioner had taken the first step to have income excluded /exempted qua said AY by filing a revised return which was rejected on the technical ground - this was first step qua section 264 application/petition well within the one year time frame - delay condoned
Condonation of delay - revision u/s 264 - as the order u/s 143(1) came to be passed within this one year itself, writ petitioner had taken the first step to have income excluded /exempted qua said AY by filing a revised return which was rejected on the technical ground - this was first step qua section 264 application/petition well within the one year time frame - delay condoned
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