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.271A - non complying the provisions of Section 44AA - failure to maintain books of accounts - there is no any specific date or nearby date when the books of accounts were got damaged by the white ant which came to the notice of the assessee that on a particular date the books of accounts have been damaged by the white ant and there is also no date as to when the hard disks were corrupted - reasonable cause under which he may get relief u/s. 273B - Penalty confirmed.
Penalty u/s.271A - non complying the provisions of Section 44AA - failure to maintain books of accounts - there is no any specific date or nearby date when the books of accounts were got damaged by the white ant which came to the notice of the assessee that on a particular date the books of accounts have been damaged by the white ant and there is also no date as to when the hard disks were corrupted - reasonable cause under which he may get relief u/s. 273B - Penalty confirmed.
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