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 penalty u/s 271(1)(c) - since no specific satisfaction has been recorded by the Ld. Assessing Officer either in the body of the assessment order or in the show cause notice issued u/s 271(1)(c) of the Act dated 02.05.2017 for initiation of penalty proceedings penalty imposed on the assessee under section 271(1)(c) is directed to be set-aside. - AT
Levy penalty u/s 271(1)(c) - since no specific satisfaction has been recorded by the Ld. Assessing Officer either in the body of the assessment order or in the show cause notice issued u/s 271(1)(c) of the Act dated 02.05.2017 for initiation of penalty proceedings penalty imposed on the assessee under section 271(1)(c) is directed to be set-aside. - AT
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