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...
Ex parte order of CIT-A - assessee had bonafide reasons for non-appearance on the scheduled date of hearing - matter restored back - In case, however, the assessee does not fully co-operate in expeditious disposal of remanded proceedings, learned CIT(A) will be at liberty to take such action, apart from disposal of appeal based on material on record, as he deems fit and proper and judicious. - AT
Ex parte order of CIT-A - assessee had bonafide reasons for non-appearance on the scheduled date of hearing - matter restored back - In case, however, the assessee does not fully co-operate in expeditious disposal of remanded proceedings, learned CIT(A) will be at liberty to take such action, apart from disposal of appeal based on material on record, as he deems fit and proper and judicious. - AT
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