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) - Assessee had not offered any reasonable cause for delay in filing of TDS statements u/s. 200(3) - The default committed by the assessee is only a minor technical and venial breach. As settled law that no penalty could be levied on an assessee for a mere technical venial breach, more especially when there is no loss caused to the exchequer due to such breach. - AT
Penalty u/s. 272A(2)(k) - Assessee had not offered any reasonable cause for delay in filing of TDS statements u/s. 200(3) - The default committed by the assessee is only a minor technical and venial breach. As settled law that no penalty could be levied on an assessee for a mere technical venial breach, more especially when there is no loss caused to the exchequer due to such breach. - AT
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