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 78 - cash crisis/ fund shortage - cash crunch could not be substantiated by it as it could generate cash of huge amount for payment within two days of visit by the departmental officials to is premises - Levy of penalty confirmed.
Penalty u/s 78 - cash crisis/ fund shortage - cash crunch could not be substantiated by it as it could generate cash of huge amount for payment within two days of visit by the departmental officials to is premises - Levy of penalty confirmed.
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