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 u/s.271BA - no affidavit from the Director or by Chartered Accountant to show that report in Form No.3CEB was obtained before the due date of filing of the return or the said Audit report was made available to the AO either before processing the return u/s.143(1) or completion of assessment order u/s.143(3) of the Act - penalty confirmed - AT
Penalty u/s.271BA - no affidavit from the Director or by Chartered Accountant to show that report in Form No.3CEB was obtained before the due date of filing of the return or the said Audit report was made available to the AO either before processing the return u/s.143(1) or completion of assessment order u/s.143(3) of the Act - penalty confirmed - AT
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