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 allowed the petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
The HC allowed the petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
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