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...
Levy of penalty u/s. 271A(2)(g) - default in compliance of TDS provision - financial crisis - The assessee has demonstrated from the material placed on record that because of financial crisis there was delay in depositing TDS, therefore, TDS return filed late which resulted in issuing TDS certificate late - neither the AO nor the Ld. CIT(A) has controverted nor disprove the contention of the assessee that there was financial crisis, therefore, we consider that the case of the assessee is covered by the provision of Section 273B of the Act - No penalty - AT
Levy of penalty u/s. 271A(2)(g) - default in compliance of TDS provision - financial crisis - The assessee has demonstrated from the material placed on record that because of financial crisis there was delay in depositing TDS, therefore, TDS return filed late which resulted in issuing TDS certificate late - neither the AO nor the Ld. CIT(A) has controverted nor disprove the contention of the assessee that there was financial crisis, therefore, we consider that the case of the assessee is covered by the provision of Section 273B of the Act - No penalty - AT
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