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 levied u/s 271E - period of limitation - The order of reassessment was not subject matter of revision proceedings u/s 263 or 264 of the Act. Hence the assessee’s case squarely falls under clause (c ) of section 275(1).
Penalty levied u/s 271E - period of limitation - The order of reassessment was not subject matter of revision proceedings u/s 263 or 264 of the Act. Hence the assessee’s case squarely falls under clause (c ) of section 275(1).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
