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...
Deletion of penalty u/s 271D – Violation of provisions of Section 269SS or not –assessee was under the bona fide impression that the money received was only towards allotment of shares and it is not a loan or deposit - no penalty - HC
Deletion of penalty u/s 271D – Violation of provisions of Section 269SS or not –assessee was under the bona fide impression that the money received was only towards allotment of shares and it is not a loan or deposit - no penalty - HC
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