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...
Computation of period for filing of appeal in stipulated time - the admitted communication date of the Order-in-Original is 23.06.2014, which has to be excluded in terms of Section 9 above. Therefore, the commencement of the period shall be from 24.06.2014 and from that date 90 days completes on 21.09.2014 - 21st September, 2014 being a last date for filing appeal falls on Sunday, therefore in terms of Section 10 the appeal could have been validly filed on 22nd September, 2014, in this case the appeal was filed on 22.09.2014. Thus, the appeal was filed well within the stipulated period of 90 days. - AT
Computation of period for filing of appeal in stipulated time - the admitted communication date of the Order-in-Original is 23.06.2014, which has to be excluded in terms of Section 9 above. Therefore, the commencement of the period shall be from 24.06.2014 and from that date 90 days completes on 21.09.2014 - 21st September, 2014 being a last date for filing appeal falls on Sunday, therefore in terms of Section 10 the appeal could have been validly filed on 22nd September, 2014, in this case the appeal was filed on 22.09.2014. Thus, the appeal was filed well within the stipulated period of 90 days. - AT
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