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 filling appeal before CIT(A) - CIT(A) dismissing the appeal of the assessee in-limine - The Appellate Tribunal recognized the appellant's explanation for the delay, noting that notices were sent to an outdated address, and the appellant became aware of the assessment order only when a lien was placed on their bank account. Considering the extraordinary circumstances, including the COVID-19 pandemic, the Tribunal condoned the delay and allowed the appeal. Recognizing the appellant's right to proper representation, the Tribunal ordered the restoration of all issues to the AO's file for re-examination, emphasizing the need for adequate opportunity and cooperation from the appellant.
Condonation of delay in filling appeal before CIT(A) - CIT(A) dismissing the appeal of the assessee in-limine - The Appellate Tribunal recognized the appellant's explanation for the delay, noting that notices were sent to an outdated address, and the appellant became aware of the assessment order only when a lien was placed on their bank account. Considering the extraordinary circumstances, including the COVID-19 pandemic, the Tribunal condoned the delay and allowed the appeal. Recognizing the appellant's right to proper representation, the Tribunal ordered the restoration of all issues to the AO's file for re-examination, emphasizing the need for adequate opportunity and cooperation from the appellant.
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