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 for technical breach of law - Wrong mention of section 272A(2)(C) in place of 272A(2)(K) - recourse Sec. 292B of the Act would also not help the case of the Revenue because the mistake cannot be said to be a pure technical objection - AT
Penalty for technical breach of law - Wrong mention of section 272A(2)(C) in place of 272A(2)(K) - recourse Sec. 292B of the Act would also not help the case of the Revenue because the mistake cannot be said to be a pure technical objection - AT
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