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...
Petitioners did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
Petitioners did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
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