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) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
Penalty u/s 271 (1)(c) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
