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...
Levy of tax and penalty - E-way Bill lost its validity - Appellate authority directed to dispose of the appeal preferred by the petitioner manually expeditiously and preferably within a period of eight weeks from the date of receipt/ production of a copy of this order, since it has been submitted by the learned counsel for the petitioner that the memo of appeal submitted manually contains all the grounds on which he has assailed the impugned order dated 19.02.2021. - HC
Levy of tax and penalty - E-way Bill lost its validity - Appellate authority directed to dispose of the appeal preferred by the petitioner manually expeditiously and preferably within a period of eight weeks from the date of receipt/ production of a copy of this order, since it has been submitted by the learned counsel for the petitioner that the memo of appeal submitted manually contains all the grounds on which he has assailed the impugned order dated 19.02.2021. - HC
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