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...
Levy of penalty u/s 158BFA(2) - when the assessee has voluntarily accepted the undisclosed income bona-fidely for the purpose of buying peace of mind and to avoid protracted litigation, there is no question of imposing penalty - AT
Levy of penalty u/s 158BFA(2) - when the assessee has voluntarily accepted the undisclosed income bona-fidely for the purpose of buying peace of mind and to avoid protracted litigation, there is no question of imposing penalty - AT
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