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 section 271(1)(c) - during survey, assessee has made voluntary surrender on account of sundry creditors and returned the additional income in the return of income filed and paid tax thereon - no penalty - AT
Penalty under section 271(1)(c) - during survey, assessee has made voluntary surrender on account of sundry creditors and returned the additional income in the return of income filed and paid tax thereon - no penalty - AT
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