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 u/s 271D - reasonable cause for violation of Section 269SS - when the Karta is dealing with the large amounts of cash. Lack of formal education cannot by itself be the conclusive of ignorance of the law, particularly in respect of men of business. - HC
Penalty u/s 271D - reasonable cause for violation of Section 269SS - when the Karta is dealing with the large amounts of cash. Lack of formal education cannot by itself be the conclusive of ignorance of the law, particularly in respect of men of business. - HC
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