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 under Sections 76, 77 and 78 - before issue of show-cause notice, the entire amount of tax was paid and before issue of adjudication order, interest was also paid - Penalty waived u/s 80 - AT
Penalty under Sections 76, 77 and 78 - before issue of show-cause notice, the entire amount of tax was paid and before issue of adjudication order, interest was also paid - Penalty waived u/s 80 - AT
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