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...
Maintainability of appeal - appeal dismissed on the ground of time limitation - non-submission of the certified copy. - Despite discrepancies raised by the respondent regarding the existence of the appeal in the online portal, the court found merit in the petitioner's submissions, affirming the timely filing of the appeal. Moreover, the court dismissed the notion that the appeal was time-barred due to the petitioner's failure to submit a certified copy of the original order, as evidence suggested otherwise. Consequently, the court set aside the impugned order and remitted the matter to the Appellate Authority for consideration on its merits in accordance with the law.
Maintainability of appeal - appeal dismissed on the ground of time limitation - non-submission of the certified copy. - Despite discrepancies raised by the respondent regarding the existence of the appeal in the online portal, the court found merit in the petitioner's submissions, affirming the timely filing of the appeal. Moreover, the court dismissed the notion that the appeal was time-barred due to the petitioner's failure to submit a certified copy of the original order, as evidence suggested otherwise. Consequently, the court set aside the impugned order and remitted the matter to the Appellate Authority for consideration on its merits in accordance with the law.
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