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. 271D - unsecured loans in the form of cash - the amount paid by the Directors / Shareholder towards share capital and unsecured loans in the form of cash does not attract the provisions of section 269SS of the Act and penalty U/s. 271D cannot be levied on the same - AT
Penalty u/s. 271D - unsecured loans in the form of cash - the amount paid by the Directors / Shareholder towards share capital and unsecured loans in the form of cash does not attract the provisions of section 269SS of the Act and penalty U/s. 271D cannot be levied on the same - AT
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