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 - delay of 583 days - Due to subsequent developments wherein the assessee runs a serious risk of prosecution where the penalty is confirmed, he was advised to file the present appeals - there exists sufficient and reasonable cause for condoning the delay of 583 days in filing the present appeals where substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserved to be preferred. I
Condonation of delay - delay of 583 days - Due to subsequent developments wherein the assessee runs a serious risk of prosecution where the penalty is confirmed, he was advised to file the present appeals - there exists sufficient and reasonable cause for condoning the delay of 583 days in filing the present appeals where substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserved to be preferred. I
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