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 of 1433 days in filing appeal before the tribunal - Tribunal condoned the delay in revenue appeal - error of law or not - In view of the facts and circumstances and the law laid down by the Supreme Court and also the sufficient cause assigned in the applications for condonation of delay, the Revenue has assigned sufficient cause for the purpose of getting the delay condoned and the Tribunal was justified in allowing the applications - HC
Condonation of delay of 1433 days in filing appeal before the tribunal - Tribunal condoned the delay in revenue appeal - error of law or not - In view of the facts and circumstances and the law laid down by the Supreme Court and also the sufficient cause assigned in the applications for condonation of delay, the Revenue has assigned sufficient cause for the purpose of getting the delay condoned and the Tribunal was justified in allowing the applications - HC
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