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...
Review of order - Levy of penalty - grounds for review are that the imposition of penalty by the authorities is not automatic and the same can be imposed only when there is a fraud or willful intention to defraud the revenue - The order under review would clearly indicate that intentional and willful non-disclosure of crucial facts can be inferred from the self-declaration made in the web-portal - there are no grounds to interfere with the order impugned in the review - HC
Review of order - Levy of penalty - grounds for review are that the imposition of penalty by the authorities is not automatic and the same can be imposed only when there is a fraud or willful intention to defraud the revenue - The order under review would clearly indicate that intentional and willful non-disclosure of crucial facts can be inferred from the self-declaration made in the web-portal - there are no grounds to interfere with the order impugned in the review - HC
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