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 notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
Penalty notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
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