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 271(1)(c) - In the given situation and particularly as the addition for benami accounts stands deleted and there is no dispute about the facts that the accounts were duly audited and pertain to a much earlier year, it is not a fit case for levy of penalty - HC
Penalty u/s 271(1)(c) - In the given situation and particularly as the addition for benami accounts stands deleted and there is no dispute about the facts that the accounts were duly audited and pertain to a much earlier year, it is not a fit case for levy of penalty - HC
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