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 - The proprietor of the firm had given a Letter of Authority to the Manager to look after the day-to-day affairs. Therefore the penalties imposed on the proprietor seems to be unwarranted as he may have been kept in dark by the Manager and the same is liable to be set aside. - AT
Levy of penalty - The proprietor of the firm had given a Letter of Authority to the Manager to look after the day-to-day affairs. Therefore the penalties imposed on the proprietor seems to be unwarranted as he may have been kept in dark by the Manager and the same is liable to be set aside. - AT
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