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 under Section 271D - Period u/s 275(i)(c) - the period of limitation for the purpose of such penalty proceedings was not to be reckoned form the issue of first show cause, but from the date of issue of first show cause for initiation of such penalty proceedings - HC
Penalty under Section 271D - Period u/s 275(i)(c) - the period of limitation for the purpose of such penalty proceedings was not to be reckoned form the issue of first show cause, but from the date of issue of first show cause for initiation of such penalty proceedings - HC
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