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/sec. 271B - assessee had entered into only a single transaction and has bonafide belief that the transaction entered into by her leads to capital gains and not business transaction AO consider the same as business income then it attracts the provisions of section 44AB - since explanation given by the assessee is bonafide and also justified, no penalty can be levied u/s 271B
Penalty u/sec. 271B - assessee had entered into only a single transaction and has bonafide belief that the transaction entered into by her leads to capital gains and not business transaction AO consider the same as business income then it attracts the provisions of section 44AB - since explanation given by the assessee is bonafide and also justified, no penalty can be levied u/s 271B
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