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)(b) - non-compliance of statutory notices - since the order was passed by the AO u/s. 143(3) and not 144 means the subsequent compliance in the assessment proceedings was considered as good compliance and default committed earlier were ignored by AO - No penalty leviable
Penalty u/s. 271(1)(b) - non-compliance of statutory notices - since the order was passed by the AO u/s. 143(3) and not 144 means the subsequent compliance in the assessment proceedings was considered as good compliance and default committed earlier were ignored by AO - No penalty leviable
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