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...
Deduction u/s. 80IC - belated return filled - if deemed fit, the assessee can still approach the Board for consideration of its case and if the Board finds merit in the reason for genuine hardship of the assessee for filing the return belatedly the case of the assessee may be considered sympathetically. If such permission is granted by the Board, then the AO can allow claim of deduction of the assessee u/s.80IC of the Act in accordance with law - AT
Deduction u/s. 80IC - belated return filled - if deemed fit, the assessee can still approach the Board for consideration of its case and if the Board finds merit in the reason for genuine hardship of the assessee for filing the return belatedly the case of the assessee may be considered sympathetically. If such permission is granted by the Board, then the AO can allow claim of deduction of the assessee u/s.80IC of the Act in accordance with law - AT
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