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 u/s. 271D r.w.s. 269SS - No penalty u/s. 271D can be levied on an assessee where the loans have been accepted in an assessment u/s. 143(3) of the Act made by the Assessing Officer as genuine.
Penalty u/s. 271D r.w.s. 269SS - No penalty u/s. 271D can be levied on an assessee where the loans have been accepted in an assessment u/s. 143(3) of the Act made by the Assessing Officer as genuine.
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