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...
Levy of penalty u/s 271E - violation of provision of section 269T - repayment of loan was made in cash - when there is nothing on record suggesting that the loan amount was repaid in cash by the assessee - imposition of penalty would not be justified
Levy of penalty u/s 271E - violation of provision of section 269T - repayment of loan was made in cash - when there is nothing on record suggesting that the loan amount was repaid in cash by the assessee - imposition of penalty would not be justified
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