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 271AAA(2) - disclosure of undisclosed income - money found during search u/s 132 - assessee has fulfilled the requirement of sub-section (2) of section 271AAA - no penalty - AT
Penalty 271AAA(2) - disclosure of undisclosed income - money found during search u/s 132 - assessee has fulfilled the requirement of sub-section (2) of section 271AAA - no penalty - AT
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