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 271AAA - disclosure of unaccounted income during search - assessee did not specify how she derived that income and what head it fell in (rent, capital gain, professional or business income out of money lending, source of the money etc) - the lower appellate authorities misdirected themselves in holding that the conditions in Section 271AAA (2) were satisfied by the assessee. - HC
Penalty u/s 271AAA - disclosure of unaccounted income during search - assessee did not specify how she derived that income and what head it fell in (rent, capital gain, professional or business income out of money lending, source of the money etc) - the lower appellate authorities misdirected themselves in holding that the conditions in Section 271AAA (2) were satisfied by the assessee. - HC
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