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...
Waiver of penalty u/s 80 - ill-health of the mother of the assessee's partner cannot be considered as a reasonable cause so as to invoke the provisions of Section 80 of the Finance Act, 1994. - AT
Waiver of penalty u/s 80 - ill-health of the mother of the assessee's partner cannot be considered as a reasonable cause so as to invoke the provisions of Section 80 of the Finance Act, 1994. - AT
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