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 u/s 272A(2)(k) - there was a delay on the part of the concerned deductees to furnish their PAN details and the same constituted a reasonable cause which prevented the assessees from filing the relevant TDS returns within the stipulated time - AO to re-adjudicate the issue - AT
Penalty u/s 272A(2)(k) - there was a delay on the part of the concerned deductees to furnish their PAN details and the same constituted a reasonable cause which prevented the assessees from filing the relevant TDS returns within the stipulated time - AO to re-adjudicate the issue - AT
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