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 221 - non payment of admitted tax - financial stringency is considered to be good and sufficient cause for sufficiency of reason for not levying penalty u/s 221(1) - when AO has not controvert the assessee’s reasons regarding paucity of funds then assessee could not be considered as willful defaulter - no penalty
Penalty u/s 221 - non payment of admitted tax - financial stringency is considered to be good and sufficient cause for sufficiency of reason for not levying penalty u/s 221(1) - when AO has not controvert the assessee’s reasons regarding paucity of funds then assessee could not be considered as willful defaulter - no penalty
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
