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 imposed u/s 271AAB - In the light of the settled proposition of law that Section 271AAB of the Act cannot be invoked to impose penalty when search has not been conducted under Section 132 of the Act against the assessee and return of income is in response to notice under Section 156C of the Act which is a consequential or incidental proceeding, - HC
Penalty imposed u/s 271AAB - In the light of the settled proposition of law that Section 271AAB of the Act cannot be invoked to impose penalty when search has not been conducted under Section 132 of the Act against the assessee and return of income is in response to notice under Section 156C of the Act which is a consequential or incidental proceeding, - HC
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