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 - If any liability arises against the partnership firm i.e. shifted on partners of partnership firm in the sharing ratio of the partners, therefore, the partners cannot be treated different then the partnership firm - AT
Imposition of penalty - If any liability arises against the partnership firm i.e. shifted on partners of partnership firm in the sharing ratio of the partners, therefore, the partners cannot be treated different then the partnership firm - AT
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