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...
Imposition of penalty on Director - Penalty being imposable on the basis of mens rea, it should be on a personnel of the Managing Director but not on his designation. Therefore, the Corrigendum which has no force in the eyes of law does not become enforceable - AT
Imposition of penalty on Director - Penalty being imposable on the basis of mens rea, it should be on a personnel of the Managing Director but not on his designation. Therefore, the Corrigendum which has no force in the eyes of law does not become enforceable - AT
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