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...
MAT - Income to be taxed u/s 115BAA or u/s 115JB - assessee has not uploaded Form 10-IC electronically before or at the time of filing of return of income within time period prescribed u/s 139(1) - the ground of appeal raised by the assessee is restored back to the file of assessing officer to consider the report in Form-10IC and allow relief to the assessee, if the assessee fulfil all other requisite condition as per law. - AT
MAT - Income to be taxed u/s 115BAA or u/s 115JB - assessee has not uploaded Form 10-IC electronically before or at the time of filing of return of income within time period prescribed u/s 139(1) - the ground of appeal raised by the assessee is restored back to the file of assessing officer to consider the report in Form-10IC and allow relief to the assessee, if the assessee fulfil all other requisite condition as per law. - AT
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