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 quashed and set aside the Tribunal's order which had refused to condone the delay of 2208 days in filing the appeal. The High Court held that the Tribunal's finding that the order was delivered at the address mentioned in Form No. 35 was perverse and contrary to the record. The delay of 2208 days in preferring the appeal was condoned by the High Court, and the matter was remanded back to the Tribunal to be decided on merits.
The High Court quashed and set aside the Tribunal's order which had refused to condone the delay of 2208 days in filing the appeal. The High Court held that the Tribunal's finding that the order was delivered at the address mentioned in Form No. 35 was perverse and contrary to the record. The delay of 2208 days in preferring the appeal was condoned by the High Court, and the matter was remanded back to the Tribunal to be decided on merits.
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