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...
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
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