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...
Quantification of penalty - power to tribunal to reduce the penalty u/s 11AC below the amount of confirmed duty - the Tribunal could not reduce the penalty for an amount lesser than the duty which has been upheld - SC
Quantification of penalty - power to tribunal to reduce the penalty u/s 11AC below the amount of confirmed duty - the Tribunal could not reduce the penalty for an amount lesser than the duty which has been upheld - SC
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