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 under section 271G of the Income tax Act – TPA - failure to furnish information and documents required by an Assessing Officer under Section 92D - The documentation or information should be one specified in Rule 10D - no penalty - HC
Penalty under section 271G of the Income tax Act – TPA - failure to furnish information and documents required by an Assessing Officer under Section 92D - The documentation or information should be one specified in Rule 10D - no penalty - HC
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