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 - repayment of the loan in cash - the completion of assessment proceedings is not a condition precedent for initiation of penalty proceedings u/s. 269T.
Levy of penalty u/s.271E - repayment of the loan in cash - the completion of assessment proceedings is not a condition precedent for initiation of penalty proceedings u/s. 269T.
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