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 4B(5) of UPTT - when the assessee in his proforma 4 and form 82 has himself declared the manufacture goods as plastic goods there was little or no evidence before the Tribunal to come to the conclusion that the goods so manufactured were packaging materials - HC
Penalty u/s 4B(5) of UPTT - when the assessee in his proforma 4 and form 82 has himself declared the manufacture goods as plastic goods there was little or no evidence before the Tribunal to come to the conclusion that the goods so manufactured were packaging materials - HC
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