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...
Initiation of prosecution - Penalty upheld by ITAT - substantial question of law relating to penalty u/s 271(1)(c) pending before High Court - at this stage, there would no question of launching prosecution - initiation of prosecution stayed.
Initiation of prosecution - Penalty upheld by ITAT - substantial question of law relating to penalty u/s 271(1)(c) pending before High Court - at this stage, there would no question of launching prosecution - initiation of prosecution stayed.
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