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...
Provisional attachment of Bank Accounts and properties - undisclosed foreign investment - exercise of powers u/s 132(9B) - while granting the relief, we must bear in mind that the approximate tax, interest and penalty liability which the Department has computed, firstly even the basis of maximum penalty which is impossible, secondly the same is in realm of possibilities.
Provisional attachment of Bank Accounts and properties - undisclosed foreign investment - exercise of powers u/s 132(9B) - while granting the relief, we must bear in mind that the approximate tax, interest and penalty liability which the Department has computed, firstly even the basis of maximum penalty which is impossible, secondly the same is in realm of possibilities.
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