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 271B - delay in filing tax audit report - reasonable / bonafide cause - The assessee is not a habitual defaulter for filing the tax audit report. Therefore, the change of auditor is one of the valid reasons for delay in filing the tax audit report. - No penalty - AT
Penalty u/s 271B - delay in filing tax audit report - reasonable / bonafide cause - The assessee is not a habitual defaulter for filing the tax audit report. Therefore, the change of auditor is one of the valid reasons for delay in filing the tax audit report. - No penalty - AT
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