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...
Imposition of penalty u/s 78 - there was a bonafide error in not recording the amount in the ST-3 return is seems to be acceptable - penalty waived - AT
Imposition of penalty u/s 78 - there was a bonafide error in not recording the amount in the ST-3 return is seems to be acceptable - penalty waived - AT
Note: It is a system-generated summary and is for quick reference only.