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 272A(2)(k) - delay in filing the TDS return - due to sudden resignation of the accountant, the assessee could not trace his left over jobs including non-filing of TDS returns and as soon the same was noticed, same were filed - there is no intentional default or motive to make any financial gain - sufficient cause for making due compliance u/s 273B - no penalty
Penalty u/s 272A(2)(k) - delay in filing the TDS return - due to sudden resignation of the accountant, the assessee could not trace his left over jobs including non-filing of TDS returns and as soon the same was noticed, same were filed - there is no intentional default or motive to make any financial gain - sufficient cause for making due compliance u/s 273B - no penalty
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