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 on CHA - There was no deliberate attempt on the part of the appellant in violating the law; therefore penalty against the appellant herein is much on the higher side, especially considering the fact that the appellant was only a small time CHA - penalty reduced - AT
Penalty on CHA - There was no deliberate attempt on the part of the appellant in violating the law; therefore penalty against the appellant herein is much on the higher side, especially considering the fact that the appellant was only a small time CHA - penalty reduced - AT
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