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) - genuineness of the claim has neither been disputed by the department nor the claimed expenses are false - the assessee has furnished all the relevant facts concerning the claim made by it in the return filed and disallowance u/s.40(a) was made for the reasons that assessee failed to deduct TDS thereon - no penalty
Penalty u/s 271(1)(c) - genuineness of the claim has neither been disputed by the department nor the claimed expenses are false - the assessee has furnished all the relevant facts concerning the claim made by it in the return filed and disallowance u/s.40(a) was made for the reasons that assessee failed to deduct TDS thereon - no penalty
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