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)(c) - non-submission of information as willful default - Addl. CIT initiated penalty proceedings by issuing only one notice but levied penalty for three notices - This indicates that without issuing notice, the Addl. CIT, CIB levied penalty three times for the same default. This cannot be justified. - AT
Penalty u/s. 272A(2)(c) - non-submission of information as willful default - Addl. CIT initiated penalty proceedings by issuing only one notice but levied penalty for three notices - This indicates that without issuing notice, the Addl. CIT, CIB levied penalty three times for the same default. This cannot be justified. - AT
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