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...
Levy of penalty - disclosure made u/s 132(4) at the time of search on undisclosed stock - the excess stock does fall under the definition of ‘undisclosed income’ and consequently penalty u/s 271AAB of the Act is leviable for the same - AT
Levy of penalty - disclosure made u/s 132(4) at the time of search on undisclosed stock - the excess stock does fall under the definition of ‘undisclosed income’ and consequently penalty u/s 271AAB of the Act is leviable for the same - AT
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