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 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
Levy of penalty u/s 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
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