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 - Looking into the delay in the proceeding which is now almost 27 year caused due to the Appellant's non-cooperation in the proceeding - delay of 3187 days not condoned - AT
Condonation of Delay - Looking into the delay in the proceeding which is now almost 27 year caused due to the Appellant's non-cooperation in the proceeding - delay of 3187 days not condoned - AT
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