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 under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
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