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) - assessee disclosed all the true facts relating to the land - it may be a good case for making addition since there was difference between the actual consideration and the stamp duty value - but not a good case where penalty u/s 271(1)(c) may be levied as It is well settled that the penalty proceedings are different and distinct from the assessment proceedings
Penalty u/s 271(1)(c) - assessee disclosed all the true facts relating to the land - it may be a good case for making addition since there was difference between the actual consideration and the stamp duty value - but not a good case where penalty u/s 271(1)(c) may be levied as It is well settled that the penalty proceedings are different and distinct from the assessment proceedings
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
