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 the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
Condonation of Delay in filing the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
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