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 271D and 271E - Accepting loans by way of cash in excess of the prescribed limit - If the assessee is able to establish that all the cash transactions are arising out of the bank withdrawals and recorded in the assesse’s books of accounts within a reasonable span of time from the date of cash withdrawals from the respective bank accounts and further if all the entities are pertaining to sister concerns (arising out of the same group of ownership), then the provisions of section 269SS and 269T will not be applicable - AT
Penalty u/s 271D and 271E - Accepting loans by way of cash in excess of the prescribed limit - If the assessee is able to establish that all the cash transactions are arising out of the bank withdrawals and recorded in the assesse’s books of accounts within a reasonable span of time from the date of cash withdrawals from the respective bank accounts and further if all the entities are pertaining to sister concerns (arising out of the same group of ownership), then the provisions of section 269SS and 269T will not be applicable - AT
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