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...
Benefit of Vivad Se Vishwas Scheme 2020 - present appeal was filed with a delay of 958 days - Addition of undisclosed income in the garb of Long Term Capital Gain (LTCG) to claim exemption u/s. 10(38) - Assessee should not be non-suited for the default committed by the revenue in nor preferring the appeal within the period of limitation. - HC
Benefit of Vivad Se Vishwas Scheme 2020 - present appeal was filed with a delay of 958 days - Addition of undisclosed income in the garb of Long Term Capital Gain (LTCG) to claim exemption u/s. 10(38) - Assessee should not be non-suited for the default committed by the revenue in nor preferring the appeal within the period of limitation. - HC
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