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...
Escapement or under-assessment under KVAT Act - mistake in reporting purchase turnover - the authorities have not found any discrepancy in the sales figures returned, or any escapement of sales turnover which is taxable - filing of incomplete or incorrect return might have attracted penalization u/s 67 but alone cannot be used to make an addition in the turnover and to demand tax
Escapement or under-assessment under KVAT Act - mistake in reporting purchase turnover - the authorities have not found any discrepancy in the sales figures returned, or any escapement of sales turnover which is taxable - filing of incomplete or incorrect return might have attracted penalization u/s 67 but alone cannot be used to make an addition in the turnover and to demand tax
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