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 272A(2)(e) - delay of 509 days in filing the return of income - Once the assessee is liable to file the return of income under the provisions of the Act and it fails to do so, then the provisions of section 272A(2)(e) of the Act automatically arises.
Levy of penalty u/s 272A(2)(e) - delay of 509 days in filing the return of income - Once the assessee is liable to file the return of income under the provisions of the Act and it fails to do so, then the provisions of section 272A(2)(e) of the Act automatically arises.
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