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 - cash received of sales of immovable property - allegation of violation of provisions of Sec.269SS - cash payment was made at one go before the subregistrar at the time of registration of sale deeds of plots - This provision will not apply to the transaction that happens at the time of final payment at the time of registration of sale deed and payment is made before sub-registrar at the time of registration of property. - AT
Penalty u/s 271D - cash received of sales of immovable property - allegation of violation of provisions of Sec.269SS - cash payment was made at one go before the subregistrar at the time of registration of sale deeds of plots - This provision will not apply to the transaction that happens at the time of final payment at the time of registration of sale deed and payment is made before sub-registrar at the time of registration of property. - AT
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