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 - there is no finding in the penalty order to this effect that undisclosed income so found and surrendered during the course of search falls under the definition of “undisclosed income” as so defined in section 271AAB and in absence thereof, on this ground itself, the impugned penalty proceedings deserve to be set-aside.
Penalty u/s 271AAB - there is no finding in the penalty order to this effect that undisclosed income so found and surrendered during the course of search falls under the definition of “undisclosed income” as so defined in section 271AAB and in absence thereof, on this ground itself, the impugned penalty proceedings deserve to be set-aside.
Note: It is a system-generated summary and is for quick reference only.