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 - nature of transaction with other party - taking or repaying cash-loans contravention of sections 269SS/269T - other party is being assessed by the same AO and enquiry was made by the AO to ascertain the facts - Additions deleted - AT
Penalty u/s 271D/271E - nature of transaction with other party - taking or repaying cash-loans contravention of sections 269SS/269T - other party is being assessed by the same AO and enquiry was made by the AO to ascertain the facts - Additions deleted - AT
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