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/r 25 of CER - the Tribunal while passing the impugned order did not give any reason as to why the penalty of ₹ 5,00,000/- should be confirmed - Penalty set aside
Penalty u/r 25 of CER - the Tribunal while passing the impugned order did not give any reason as to why the penalty of ₹ 5,00,000/- should be confirmed - Penalty set aside
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