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...
Imposition of penalty - having regard to the first proviso which was effective from 04.04.2011 till the effective date of implementation of Finance Bill of 2015, appellant is liable to pay 50% of the duty demand as penalty.
Imposition of penalty - having regard to the first proviso which was effective from 04.04.2011 till the effective date of implementation of Finance Bill of 2015, appellant is liable to pay 50% of the duty demand as penalty.
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