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 - Though there is a considerable delay in filing the appeal, but having regard to the fact that the applicant had approached High Court and, thereafter, had filed a Miscellaneous Application before the Tribunal we consider it appropriate to condone the delay but on imposition of cost upon the Appellant - AT
Condonation of delay - Though there is a considerable delay in filing the appeal, but having regard to the fact that the applicant had approached High Court and, thereafter, had filed a Miscellaneous Application before the Tribunal we consider it appropriate to condone the delay but on imposition of cost upon the Appellant - AT
Note: It is a system-generated summary and is for quick reference only.