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 High Court addressed the issue of time limitation in filing an appeal, specifically focusing on the condonation of delay. The appeal was filed beyond the prescribed time limit, and the key ground for rejecting it was the date of physical re-filing. The Court noted that the appeal was initially filed online on a specific date, and the subsequent physical filing occurred later. A rule change regarding the date of appeal filing was discussed, emphasizing the importance of the acknowledgment date. The Court concluded that the delay should be condoned as per the amended rule, directing a fresh consideration of the matter. The petition was disposed of accordingly.
The High Court addressed the issue of time limitation in filing an appeal, specifically focusing on the condonation of delay. The appeal was filed beyond the prescribed time limit, and the key ground for rejecting it was the date of physical re-filing. The Court noted that the appeal was initially filed online on a specific date, and the subsequent physical filing occurred later. A rule change regarding the date of appeal filing was discussed, emphasizing the importance of the acknowledgment date. The Court concluded that the delay should be condoned as per the amended rule, directing a fresh consideration of the matter. The petition was disposed of accordingly.
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