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 imposed u/s 272A(2)(c) - Since there is no reasonable cause furnished by the assessee as mentioned u/s 273 of the IT Act for non furnishing of information sought by the ITO(intelligence) u/s 133(6) of the Act it is of the view that the order imposing penalty cannot be quashed. - AT
Penalty imposed u/s 272A(2)(c) - Since there is no reasonable cause furnished by the assessee as mentioned u/s 273 of the IT Act for non furnishing of information sought by the ITO(intelligence) u/s 133(6) of the Act it is of the view that the order imposing penalty cannot be quashed. - AT
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