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 orders passed u/s 271D and 271E - Violation of provisions of section 269SS and 269T while taking/returning the loan in cash - the nature of transaction is not loan but a business advance for purchase of machinery - No penalty.
Penalty orders passed u/s 271D and 271E - Violation of provisions of section 269SS and 269T while taking/returning the loan in cash - the nature of transaction is not loan but a business advance for purchase of machinery - No penalty.
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