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 271(1)(c) - Excess depreciation claim - it is merely a case of difference arising out of the reworking of the carry forward depreciation by the AO by allowing more depreciation than claimed by the assessee company and not a case of concealing of income or furnishing of inaccurate of particulars of income. - No penalty - AT
Penalty u/s 271(1)(c) - Excess depreciation claim - it is merely a case of difference arising out of the reworking of the carry forward depreciation by the AO by allowing more depreciation than claimed by the assessee company and not a case of concealing of income or furnishing of inaccurate of particulars of income. - No penalty - AT
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