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 - assessee has not been able to show any reasonable cause for not complying with Rules nor for its failure to produce information called for by the ld. TPO. - levy of penalty u/s 271AA as well as 271G of the Act were justified.
Penalty - assessee has not been able to show any reasonable cause for not complying with Rules nor for its failure to produce information called for by the ld. TPO. - levy of penalty u/s 271AA as well as 271G of the Act were justified.
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