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 221 - Delay in the remittance of TDS to the Government (TDS) Account - the explanation of the assessee that on account of cash crunch, remittance of TDS into Government account could not be made has not been rebutted - no penalty - AT
Levy of penalty u/s 221 - Delay in the remittance of TDS to the Government (TDS) Account - the explanation of the assessee that on account of cash crunch, remittance of TDS into Government account could not be made has not been rebutted - no penalty - AT
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