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) - voluntary surrender on account of long term capital gain on sale of shares during assessment proceedings - the surrender made by the assessee is voluntary, for which only addition can be made and penalty u/s 271(1)(c) cannot be initiated.
Penalty u/s 271(1)(c) - voluntary surrender on account of long term capital gain on sale of shares during assessment proceedings - the surrender made by the assessee is voluntary, for which only addition can be made and penalty u/s 271(1)(c) cannot be initiated.
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