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) - ITAT deleted the penalty - Additions u/s 41(1) - one time settlement with the SBI - Bank has waived a sum including interest - assessee has not furnished bifurcation of principal and interest amount in the total amount waived off by the bank - Penalty deleted by ITAT got confirmed.
Levy of penalty u/s 271(1)(c) - ITAT deleted the penalty - Additions u/s 41(1) - one time settlement with the SBI - Bank has waived a sum including interest - assessee has not furnished bifurcation of principal and interest amount in the total amount waived off by the bank - Penalty deleted by ITAT got confirmed.
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