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...
Personal Penalty under Rule 26 - department could not bring out that he was looking after the day to day working of the factory and they could not bring out any knowledge on the part of the appellant in the shortage found in the factory. - Penalty waived - AT
Personal Penalty under Rule 26 - department could not bring out that he was looking after the day to day working of the factory and they could not bring out any knowledge on the part of the appellant in the shortage found in the factory. - Penalty waived - AT
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