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...
Waiver/ reduction of penalty u/s 273A - poser of commissioner to reduce or waive penalty imposed under sections 271(1)(a) and 273(2(c) - CIT rejected the application - matter remanded back to CIT - HC
Waiver/ reduction of penalty u/s 273A - poser of commissioner to reduce or waive penalty imposed under sections 271(1)(a) and 273(2(c) - CIT rejected the application - matter remanded back to CIT - HC
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