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. 271(1)(c) - recording of specific finding or not? - In para 7 of the penalty order u/s. 271(1)(c), the Assessing Officer held that it is found to be a fit case to levy penalty u/s. 271(1)(c) of the I.T. Act, 1961, for furnishing of inaccurate particulars and concealment of income, which indicate that Assessing Officer has not recorded specific finding in respect of reason for imposing penalty in the final penalty order. - AT
Penalty u/s. 271(1)(c) - recording of specific finding or not? - In para 7 of the penalty order u/s. 271(1)(c), the Assessing Officer held that it is found to be a fit case to levy penalty u/s. 271(1)(c) of the I.T. Act, 1961, for furnishing of inaccurate particulars and concealment of income, which indicate that Assessing Officer has not recorded specific finding in respect of reason for imposing penalty in the final penalty order. - AT
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