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 271B - delay in submitting audit report - AO has not given any adverse finding that it affected the proper computation of income - the breach remains a technical breach of the procedural requirement - No penalty - AT
Penalty u/s 271B - delay in submitting audit report - AO has not given any adverse finding that it affected the proper computation of income - the breach remains a technical breach of the procedural requirement - No penalty - AT
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