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 in filing appeal - though the Appellant had filed Appeal beyond the statutory period of 60(sixty) days, but it was filed within the condonable period of 30(thirty) days. However, the Ld.Commissioner(Appeals) chose not to condone the delay and rejected the Appeal before him without going into the merits of the case. - delay condoned - matter restored back - AT
Condonation of delay in filing appeal - though the Appellant had filed Appeal beyond the statutory period of 60(sixty) days, but it was filed within the condonable period of 30(thirty) days. However, the Ld.Commissioner(Appeals) chose not to condone the delay and rejected the Appeal before him without going into the merits of the case. - delay condoned - matter restored back - AT
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