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 271AAB - discrepancy in stock - condition of Explanation(c) below section 271AAB(3) fulfilled - shortage of stock not accounted for by the assessee has been rightly qualify as “undisclosed income” as per the definition u/s 271AAB - penalty upheld
Penalty u/s 271AAB - discrepancy in stock - condition of Explanation(c) below section 271AAB(3) fulfilled - shortage of stock not accounted for by the assessee has been rightly qualify as “undisclosed income” as per the definition u/s 271AAB - penalty upheld
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