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 271(1)(c) - treating capital expenditure as revenue expenditure in the absence of any revenue recognition - t the assessee demonstrated that it had acted bonfidely on the basis of guidance notes of the ICAI and on the basis of accounting of such expenses in the earlier years, etc. - No penalty - AT
Penalty u/s 271(1)(c) - treating capital expenditure as revenue expenditure in the absence of any revenue recognition - t the assessee demonstrated that it had acted bonfidely on the basis of guidance notes of the ICAI and on the basis of accounting of such expenses in the earlier years, etc. - No penalty - AT
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