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 271(1)(c) - Quantum additions upheld by all the appellate authorities - in absence of cogent incriminating material to show that the assessee had infact furnished inaccurate particulars of income or had concealed its particulars of income, penalty u/s 271(1)(c) is not leviable
Penalty u/s 271(1)(c) - Quantum additions upheld by all the appellate authorities - in absence of cogent incriminating material to show that the assessee had infact furnished inaccurate particulars of income or had concealed its particulars of income, penalty u/s 271(1)(c) is not leviable
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