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 proceedings u/s 271D - violation of provisions of section 269SS - receipt of loan in cash - the assessee has taken a loan from his wife due to business expediency and the AO has not doubted the genuineness and the sources of the loan - no penalty.
Penalty proceedings u/s 271D - violation of provisions of section 269SS - receipt of loan in cash - the assessee has taken a loan from his wife due to business expediency and the AO has not doubted the genuineness and the sources of the loan - no penalty.
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