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...
Levying penalty u/s 272A(1)(d) - non-compliance of correspondences for special audit u/s 142(2A) - AO has written a letter to the Auditor for special audit of four case including the appellants but, the AO had never issue a specific notice with point of special audit to the appellant assessee u/s 142(2A) of the Act with the Approval of the PCIT. - No penalty - AT
Levying penalty u/s 272A(1)(d) - non-compliance of correspondences for special audit u/s 142(2A) - AO has written a letter to the Auditor for special audit of four case including the appellants but, the AO had never issue a specific notice with point of special audit to the appellant assessee u/s 142(2A) of the Act with the Approval of the PCIT. - No penalty - AT
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