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 271D - contravention of provisions of Section 269SS - Cash transaction between the Company and its Director - a. cash utilized for purchase of stamps - b. cash deposited in the bank account of the compnay by the Director - It could not be shown as to why the transactions could not be undertaken in compliance with the prescribed modes u/s 269SS. - Levy of penalty confirmed - AT
Penalty u/s 271D - contravention of provisions of Section 269SS - Cash transaction between the Company and its Director - a. cash utilized for purchase of stamps - b. cash deposited in the bank account of the compnay by the Director - It could not be shown as to why the transactions could not be undertaken in compliance with the prescribed modes u/s 269SS. - Levy of penalty confirmed - AT
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