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 levied u/s 271(1)(c) - merely on the basis of additions, AO would not ipso facto lead to the conclusion that the assessee has concealed the particulars of income or furnished inaccurate particulars of income when there is no such allegation by the AO that the assessee has not furnished all relevant particulars and details in respect of this claim - AT
Penalty levied u/s 271(1)(c) - merely on the basis of additions, AO would not ipso facto lead to the conclusion that the assessee has concealed the particulars of income or furnished inaccurate particulars of income when there is no such allegation by the AO that the assessee has not furnished all relevant particulars and details in respect of this claim - AT
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