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 271(1)(c) - Extension of Period of limitation which has otherwise expired - transferred from one officer to another officer - the three situations envisaged in Section 275 of the Act clearly do not cover the situation in the present case.
Levy of penalty u/s 271(1)(c) - Extension of Period of limitation which has otherwise expired - transferred from one officer to another officer - the three situations envisaged in Section 275 of the Act clearly do not cover the situation in the present case.
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