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...
Non filling of Electronic appeal - appeals filed by the assessee filled physically - the revenue can not take the benefit of non functioning/ malfunctioning of its portal and deny the statutory right of the assesse. In any case the assessee can not be non suited for abrastion in the portal of the revenue. - CIT(A) is directed to decide the appeals filed by the assessee filled physically as well as electronically on merit - AT
Non filling of Electronic appeal - appeals filed by the assessee filled physically - the revenue can not take the benefit of non functioning/ malfunctioning of its portal and deny the statutory right of the assesse. In any case the assessee can not be non suited for abrastion in the portal of the revenue. - CIT(A) is directed to decide the appeals filed by the assessee filled physically as well as electronically on merit - AT
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