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...
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
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