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 levied u/s 271F - assessee had failed to furnish return of income within due date - from the submission of assessee, we find that the assessee has a reasonable cause for not filing the return of income on the pretext that he is not having taxable income. AO has not brought on record that the assessee is habitual in filing return belatedly. - AT
Penalty levied u/s 271F - assessee had failed to furnish return of income within due date - from the submission of assessee, we find that the assessee has a reasonable cause for not filing the return of income on the pretext that he is not having taxable income. AO has not brought on record that the assessee is habitual in filing return belatedly. - AT
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