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...
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
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