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 set aside the final assessment order and demand notice issued by the Income Tax department. The petitioner had filed an application u/s 35-A of the Income Tax Act manually, but failed to e-file the acknowledged copy of the application in Form No. 35-A despite repeated attempts between 29.12.2023 and 31.12.2023 due to technical glitches and bona fide reasons. The Court remitted the matter back to the Income Tax department for fresh reconsideration, accepting the petitioner's assertion that the failure to e-file was due to unavoidable circumstances and sufficient cause.
The High Court set aside the final assessment order and demand notice issued by the Income Tax department. The petitioner had filed an application u/s 35-A of the Income Tax Act manually, but failed to e-file the acknowledged copy of the application in Form No. 35-A despite repeated attempts between 29.12.2023 and 31.12.2023 due to technical glitches and bona fide reasons. The Court remitted the matter back to the Income Tax department for fresh reconsideration, accepting the petitioner's assertion that the failure to e-file was due to unavoidable circumstances and sufficient cause.
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