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...
Maintainability of appeal - low tax effect - the case was reopened on the basis of revenue audit objection and in such circumstances, the same would be covered under the exception mentioned in the Circular No.3/2018 of the CBDT - Tribunal ought to have decided the issue on merits rather than dismissing the appeal on the ground of low tax effect - Tribunal order set aside
Maintainability of appeal - low tax effect - the case was reopened on the basis of revenue audit objection and in such circumstances, the same would be covered under the exception mentioned in the Circular No.3/2018 of the CBDT - Tribunal ought to have decided the issue on merits rather than dismissing the appeal on the ground of low tax effect - Tribunal order set aside
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