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...
Assessee filed second rectification application u/s 254, raising same grounds as first miscellaneous application which was already rejected. Tribunal held that except for certain documents, no evidence was available regarding payment of ESI and EPF within due dates as claimed. Second miscellaneous application filed within six months but on same grounds as first, hence not maintainable as per Smt. Vasantben H. Sheth case. Tribunal reiterated that Assessing Officer shall pass consequential order in compliance with Tribunal's order in Manikandan Vazhukkapara Kumaran case. Tribunal cannot entertain second miscellaneous application on same grounds after rejecting first.
Assessee filed second rectification application u/s 254, raising same grounds as first miscellaneous application which was already rejected. Tribunal held that except for certain documents, no evidence was available regarding payment of ESI and EPF within due dates as claimed. Second miscellaneous application filed within six months but on same grounds as first, hence not maintainable as per Smt. Vasantben H. Sheth case. Tribunal reiterated that Assessing Officer shall pass consequential order in compliance with Tribunal's order in Manikandan Vazhukkapara Kumaran case. Tribunal cannot entertain second miscellaneous application on same grounds after rejecting first.
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