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...
Limitation – Notice for penalty u/s 271(1)(c) - the notice under Section 271(1)(c) of the Act was handed over to the counsel on 13.03.1989, and by then, the time available for completion of assessment was already over on 31.03.1988 - no penalty - HC
Limitation – Notice for penalty u/s 271(1)(c) - the notice under Section 271(1)(c) of the Act was handed over to the counsel on 13.03.1989, and by then, the time available for completion of assessment was already over on 31.03.1988 - no penalty - HC
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