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 - Principles of natural justice - notice was not served on the person on whom penalty was levied, but on the driver of vehicle - there has been more than a technical infringement of the statutory provision as no hearing whatsoever was granted to the petitioner - matter remanded back.
Levy of penalty - Principles of natural justice - notice was not served on the person on whom penalty was levied, but on the driver of vehicle - there has been more than a technical infringement of the statutory provision as no hearing whatsoever was granted to the petitioner - matter remanded back.
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