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 u/s 271B - assessee did not file tax audit report u/s.44AB before the due date of filing of return of income 139(1) - since the audit report was obtained before the due date and furnished before the AO when asked, No penalty in view the circular - AT
Levy of penalty u/s 271B - assessee did not file tax audit report u/s.44AB before the due date of filing of return of income 139(1) - since the audit report was obtained before the due date and furnished before the AO when asked, No penalty in view the circular - AT
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