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 158BFA (2) - the party seeking protection from the penalty must file return pursuant to notice under section 158BD. - 'Nil return filed does not satisfy the proviso. - HC
Penalty u/s 158BFA (2) - the party seeking protection from the penalty must file return pursuant to notice under section 158BD. - 'Nil return filed does not satisfy the proviso. - HC
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