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. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
Penalty u/s. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
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