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...
Dismissal of the appeal by CIT(Appeals) for non-prosecution - The CIT(A) upheld the AO's decision due to the assessee's failure to respond to multiple hearing notices and provide necessary documents or submissions. The Tribunal, however, disagreed with the CIT(A)'s approach, emphasizing the obligation to dispose of the appeal on its merits rather than summarily dismissing it for non-prosecution. - The Tribunal set aside the CIT(A)'s order and directed a re-hearing on the merits of the appeal.
Dismissal of the appeal by CIT(Appeals) for non-prosecution - The CIT(A) upheld the AO's decision due to the assessee's failure to respond to multiple hearing notices and provide necessary documents or submissions. The Tribunal, however, disagreed with the CIT(A)'s approach, emphasizing the obligation to dispose of the appeal on its merits rather than summarily dismissing it for non-prosecution. - The Tribunal set aside the CIT(A)'s order and directed a re-hearing on the merits of the appeal.
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