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)(b) - non-compliance of the notices - assessee did not participate in the assessment proceedings and ex parte order u/s 144 was passed - Even before us, after filing of the appeal, nobody has appeared. This appears to be a repeated pattern being adopted by the assessee to misuse the due process of law. - AT
Penalty u/s 271(1)(b) - non-compliance of the notices - assessee did not participate in the assessment proceedings and ex parte order u/s 144 was passed - Even before us, after filing of the appeal, nobody has appeared. This appears to be a repeated pattern being adopted by the assessee to misuse the due process of law. - AT
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