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 filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
Condonation of delay in filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
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