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...
Non remittence of TDS in time - penal action initiated by the Income Tax Department against the petitioners - criminal proceedings - the petitioners though deducted tax at source, not paid the same within the time prescribed. This action of initiating criminal prosecution after obtaining sanction from the appropriate authority cannot be termed as violative of principles of natural justice.
Non remittence of TDS in time - penal action initiated by the Income Tax Department against the petitioners - criminal proceedings - the petitioners though deducted tax at source, not paid the same within the time prescribed. This action of initiating criminal prosecution after obtaining sanction from the appropriate authority cannot be termed as violative of principles of natural justice.
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