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 u/s 271AAB - undisclosed income - AO’s action penalizing the assessee qua the said disclosed / duly recorded income is found to be not sustainable therefore. - AO directed to re-compute the penalty only towards undisclosed income - AT
Penalty u/s 271AAB - undisclosed income - AO’s action penalizing the assessee qua the said disclosed / duly recorded income is found to be not sustainable therefore. - AO directed to re-compute the penalty only towards undisclosed income - AT
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