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 271(1)(c) - Claim of depreciation on leased assets - The transactions entered into by the assessee were sham and bogus transactions which were intended to defeat the provisions of law - AT
Levy of penalty u/s 271(1)(c) - Claim of depreciation on leased assets - The transactions entered into by the assessee were sham and bogus transactions which were intended to defeat the provisions of law - AT
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