Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
TP adjustment - goods Exported to the Associated Enterprises (AE) - The Tribunal sided with the assessee, noting the principle of consistency should apply, as similar methodologies were accepted in previous years. They directed the deletion of the transfer pricing adjustment, emphasizing that the profitability of AEs in initial operational stages in new markets can justifiably be lower.
TP adjustment - goods Exported to the Associated Enterprises (AE) - The Tribunal sided with the assessee, noting the principle of consistency should apply, as similar methodologies were accepted in previous years. They directed the deletion of the transfer pricing adjustment, emphasizing that the profitability of AEs in initial operational stages in new markets can justifiably be lower.
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