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 appeal - The appellant is a sole proprietorship firm and the Proprietor is aged about 70 years, therefore, we are of the view that the reasons given by the appellant for delay are sufficient to be condoned, more so for the reason that the delay is only of 27 days, which falls within the period of 30 days - Delay condoned - AT
Condonation of delay in filing appeal - The appellant is a sole proprietorship firm and the Proprietor is aged about 70 years, therefore, we are of the view that the reasons given by the appellant for delay are sufficient to be condoned, more so for the reason that the delay is only of 27 days, which falls within the period of 30 days - Delay condoned - AT
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