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...
Levy of penalty u/s 271D - accepting cash loans and advances beyond the prescribed limit - The pleading of assessee that the cash was required to meet urgent business requirements is also negated by the findings of fact by the AO that the assessee had sufficient funds in its banks accounts on the day it took cash loans from the directors and the days on which the expenses were made were bank working days - Additions confirmed - AT
Levy of penalty u/s 271D - accepting cash loans and advances beyond the prescribed limit - The pleading of assessee that the cash was required to meet urgent business requirements is also negated by the findings of fact by the AO that the assessee had sufficient funds in its banks accounts on the day it took cash loans from the directors and the days on which the expenses were made were bank working days - Additions confirmed - AT
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