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...
HC condoned delay in filing appeal by small partnership firm, setting aside appellate authority's rejection. Court found appellate authority erroneously limited condonation to one-month period beyond prescribed time, contradicting precedent in S.K. Chakraborty case. Considering petitioner's bona fide intent and absence of deliberate delay, HC directed appellate authority to hear appeal on merits within eight weeks. Court emphasized appellate authority's failure to properly exercise jurisdiction in mechanically rejecting appeal on limitation grounds without adequately considering explanation for delay. Appeal to be heard after giving petitioners opportunity of hearing.
HC condoned delay in filing appeal by small partnership firm, setting aside appellate authority's rejection. Court found appellate authority erroneously limited condonation to one-month period beyond prescribed time, contradicting precedent in S.K. Chakraborty case. Considering petitioner's bona fide intent and absence of deliberate delay, HC directed appellate authority to hear appeal on merits within eight weeks. Court emphasized appellate authority's failure to properly exercise jurisdiction in mechanically rejecting appeal on limitation grounds without adequately considering explanation for delay. Appeal to be heard after giving petitioners opportunity of hearing.
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