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 the Income tax returns on the specified due date u/s 119(2)(b) - As per petitioner due to covid-19 pandemic and due to change of Auditors, bonafide reasons, unavoidable circumstances and sufficient cause delay occured - having regard to the fact that the delay in filing the returns is less than one year, which cannot be said as long or inordinate delay or laches on the part of the petitioner ITR - Assessee permitted to submit returns within 3 months - HC
Condonation of delay in filing the Income tax returns on the specified due date u/s 119(2)(b) - As per petitioner due to covid-19 pandemic and due to change of Auditors, bonafide reasons, unavoidable circumstances and sufficient cause delay occured - having regard to the fact that the delay in filing the returns is less than one year, which cannot be said as long or inordinate delay or laches on the part of the petitioner ITR - Assessee permitted to submit returns within 3 months - HC
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