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...
The Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
The Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
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