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) - Additions based on difference in TDS statement (Form 26AS) - assessee failed to submit reconciliation between the books of account and Form 26AS before the AO either during assessment proceedings or during the penalty proceeding or even before the first appellate authority and even before at the time of hearing of the instant appeal - penalty upheld
Penalty u/s 271(1)(c) - Additions based on difference in TDS statement (Form 26AS) - assessee failed to submit reconciliation between the books of account and Form 26AS before the AO either during assessment proceedings or during the penalty proceeding or even before the first appellate authority and even before at the time of hearing of the instant appeal - penalty upheld
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