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 levied u/s 271B - delay in furnishing audit report - bonafide belief - Delay in furnishing audit report has resulted only in technical venial breach which does not cause any loss to exchequer could be applied here also. - levy of penalty deleted.
Penalty levied u/s 271B - delay in furnishing audit report - bonafide belief - Delay in furnishing audit report has resulted only in technical venial breach which does not cause any loss to exchequer could be applied here also. - levy of penalty deleted.
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