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 217B - not getting the books audited - once the penalty is levied for non-maintenance of book of accounts (u/s 44AA), there cannot be further default for not getting the same audited as required u/s 44AB of the Act and therefore, the penalty levied u/s 271B is not justified and thus vacated - AT
Penalty u/s 217B - not getting the books audited - once the penalty is levied for non-maintenance of book of accounts (u/s 44AA), there cannot be further default for not getting the same audited as required u/s 44AB of the Act and therefore, the penalty levied u/s 271B is not justified and thus vacated - AT
Note: It is a system-generated summary and is for quick reference only.