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 HC addressed systemic delays in appeals at the National Faceless Appeal Centre (NFAC), acknowledging the significant backlog of pending statutory appeals. While recognizing the need for expeditious resolution, the court refrained from issuing specific directives. The HC expressed confidence that NFAC would implement internal remedial measures to accelerate appeal disposals. Ultimately, the petition was disposed of without mandating explicit procedural interventions, leaving NFAC to independently address its administrative challenges and reduce pendency through its own strategic mechanisms.
The HC addressed systemic delays in appeals at the National Faceless Appeal Centre (NFAC), acknowledging the significant backlog of pending statutory appeals. While recognizing the need for expeditious resolution, the court refrained from issuing specific directives. The HC expressed confidence that NFAC would implement internal remedial measures to accelerate appeal disposals. Ultimately, the petition was disposed of without mandating explicit procedural interventions, leaving NFAC to independently address its administrative challenges and reduce pendency through its own strategic mechanisms.
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