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 u/s 271(1)(c) - Defective notice - the A.O. merely mentioned at the bottom of the assessment order after computing the income that “penalty proceedings under section 271(1)(c) of the I.T. Act have been initiated separately.” Thus there is a violation of the Law in the matter.
Levy of penalty u/s 271(1)(c) - Defective notice - the A.O. merely mentioned at the bottom of the assessment order after computing the income that “penalty proceedings under section 271(1)(c) of the I.T. Act have been initiated separately.” Thus there is a violation of the Law in the matter.
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