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...
Time Limitation - Rejection of appeal filed by the petitioner - Physical copies being submitted on 24.04.2023, beyond the condonable period while electronic filing was within the time limit - The Court found that the petitioner substantially complied with the filing requirements by referencing the assessment order already available on the department website while filing the appeal electronically. The Court held that the appeal was filed within time and remitted the matter back to the 1st respondent for registration and decision according to the law and rules. The approach of the 1st respondent in considering the physical filing date was deemed unacceptable, emphasizing that electronic filing is a facilitation for taxpayers.
Time Limitation - Rejection of appeal filed by the petitioner - Physical copies being submitted on 24.04.2023, beyond the condonable period while electronic filing was within the time limit - The Court found that the petitioner substantially complied with the filing requirements by referencing the assessment order already available on the department website while filing the appeal electronically. The Court held that the appeal was filed within time and remitted the matter back to the 1st respondent for registration and decision according to the law and rules. The approach of the 1st respondent in considering the physical filing date was deemed unacceptable, emphasizing that electronic filing is a facilitation for taxpayers.
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