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 & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
Penalty u/s 271D & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
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