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 271(1)(c) - debatable issue arises - partial income not offered to tax - revenue from web hosting services - income in the nature of royalty or not - since the matter is debatable and still to attain the finality, levy of penalty is not sustainable - AT
Penalty u/s 271(1)(c) - debatable issue arises - partial income not offered to tax - revenue from web hosting services - income in the nature of royalty or not - since the matter is debatable and still to attain the finality, levy of penalty is not sustainable - AT
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