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 271AAA - declaration of undisclosed income - voluntary or not - CIT(A) confirmed the levy of penalty - income was declared in the ITR post search but not u/s 132(4) - The assessee failed to support its claim and no material is placed before us to rebut the finding of learned CIT(Appeals) - Levy of Penalty confirmed - AT
Penalty u/s 271AAA - declaration of undisclosed income - voluntary or not - CIT(A) confirmed the levy of penalty - income was declared in the ITR post search but not u/s 132(4) - The assessee failed to support its claim and no material is placed before us to rebut the finding of learned CIT(Appeals) - Levy of Penalty confirmed - AT
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