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...
Appellate authority erred in dismissing appeal solely on ground of lack of authorisation of signatory, without affording opportunity to establish authorisation or provide resolution conferring necessary powers. Such denial violates principles of natural justice, fair play, and unduly burdens court's docket. Impugned order set aside, appeal restored for fresh consideration on merits as per law by Commissioner (Appeals). Dismissal shortcut disapproved, appellants entitled to substantive adjudication.
Appellate authority erred in dismissing appeal solely on ground of lack of authorisation of signatory, without affording opportunity to establish authorisation or provide resolution conferring necessary powers. Such denial violates principles of natural justice, fair play, and unduly burdens court's docket. Impugned order set aside, appeal restored for fresh consideration on merits as per law by Commissioner (Appeals). Dismissal shortcut disapproved, appellants entitled to substantive adjudication.
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