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...
Penalty for failure to comply with statutory notices under section 142(1) was held unsustainable where the assessee proved reasonable cause under section 273B. The Tribunal accepted the explanation that non-compliance arose from a medical condition and was not deliberate or intentional, so the protective exception applied and penalty under section 272A(1)(d) was deleted.
Penalty for failure to comply with statutory notices under section 142(1) was held unsustainable where the assessee proved reasonable cause under section 273B. The Tribunal accepted the explanation that non-compliance arose from a medical condition and was not deliberate or intentional, so the protective exception applied and penalty under section 272A(1)(d) was deleted.
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