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 221(1) - The assessee has been paying said liability in installments and in the process, it is possible that assessee may have forgotten to make the payment of self-assessment tax - penalty waived - AT
Penalty u/s 221(1) - The assessee has been paying said liability in installments and in the process, it is possible that assessee may have forgotten to make the payment of self-assessment tax - penalty waived - AT
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