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...
Cognizance for the offence u/s 276C(1) - enquiry by the investigation wing - unusual credit of large amount through RTGS in bank account maintained by the petitioner and funds were debited for investment in the stock market - There is no requirement under the Act that the assessment proceedings should be completed before lunching prosecution. Respondent has rightly lodged the complaint as against the petitioner for the offences u/s 276C(1) of the Income Tax Act, 1961. - HC
Cognizance for the offence u/s 276C(1) - enquiry by the investigation wing - unusual credit of large amount through RTGS in bank account maintained by the petitioner and funds were debited for investment in the stock market - There is no requirement under the Act that the assessment proceedings should be completed before lunching prosecution. Respondent has rightly lodged the complaint as against the petitioner for the offences u/s 276C(1) of the Income Tax Act, 1961. - HC
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