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 an appeal - Commissioner (Appeals) has vested discretionary power to condone delay beyond first 3 months if appeal is within next 3 months. - AT
Condonation of delay in filing an appeal - Commissioner (Appeals) has vested discretionary power to condone delay beyond first 3 months if appeal is within next 3 months. - AT
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