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 - suo motu revision of order passed by learned Commissioner under Section 84 of the Finance Act, 1994 imposing penalty under section 77 of the said Act followed by penalty under Section 78 - AT
Penalty - suo motu revision of order passed by learned Commissioner under Section 84 of the Finance Act, 1994 imposing penalty under section 77 of the said Act followed by penalty under Section 78 - AT
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