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...
Rectification of mistake - when there is no provision for condonation of delay for filing of the miscellaneous application, then the miscellaneous application filed belatedly is not maintainable being barred by limitation provided under section 254(2) of the Act. Miscellaneous application so filed by the assessee is dismissed. - AT
Rectification of mistake - when there is no provision for condonation of delay for filing of the miscellaneous application, then the miscellaneous application filed belatedly is not maintainable being barred by limitation provided under section 254(2) of the Act. Miscellaneous application so filed by the assessee is dismissed. - AT
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