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 issue of condonation of delay in filing appeals, which exceeded 400 days, due to unexplained cash deposits and protective additions made in the hands of the assessee. The assessee believed the protective addition would be deleted after the substantive addition was removed by the tribunal. The delay was attributed to bonafide reasons, as the assessee acted on advice and filed a rectification application, showing no malafide intention. The Tribunal held that the income from unexplained cash deposits should be assessed in the hands of the society, not the individual, and deleted the protective additions made in the assessee's hands.
The Appellate Tribunal considered the issue of condonation of delay in filing appeals, which exceeded 400 days, due to unexplained cash deposits and protective additions made in the hands of the assessee. The assessee believed the protective addition would be deleted after the substantive addition was removed by the tribunal. The delay was attributed to bonafide reasons, as the assessee acted on advice and filed a rectification application, showing no malafide intention. The Tribunal held that the income from unexplained cash deposits should be assessed in the hands of the society, not the individual, and deleted the protective additions made in the assessee's hands.
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