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...
Offence under FEMA - Eligible charge against petitioner in SCN - repatriation of sale proceeds to person resident outside India and that acquisition and transfer of immovable property by her heirs residing outside India - It is essential for a show cause notice to indicate the precise scope of the notice and also to indicate the points on which the recipient of the show cause notice give a reply. - HC
Offence under FEMA - Eligible charge against petitioner in SCN - repatriation of sale proceeds to person resident outside India and that acquisition and transfer of immovable property by her heirs residing outside India - It is essential for a show cause notice to indicate the precise scope of the notice and also to indicate the points on which the recipient of the show cause notice give a reply. - HC
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