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 u/s 22(2) of the TNGST - Having regard to the patent illegality on account of absence of jurisdiction as per the proviso as it stood during the relevant assessment year - Order of Tribunal set aside - HC
Penalty u/s 22(2) of the TNGST - Having regard to the patent illegality on account of absence of jurisdiction as per the proviso as it stood during the relevant assessment year - Order of Tribunal set aside - HC
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