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...
Quantum of redemption fine and penalty - misdeclaration of description and value - The redemption fine imposed by the Ld. Commissioner (Appeal) is sufficient in the interest of justice. Further, in the impugned order, the Ld. Commissioner (Appeal) recorded the finding that there is no finding given by the adjudicating authority for imposing the penalty under Section 117 of the Act. In that circumstances, the Ld. Commissioner(Appeal) has rightly dropped the penalty against the respondent. - AT
Quantum of redemption fine and penalty - misdeclaration of description and value - The redemption fine imposed by the Ld. Commissioner (Appeal) is sufficient in the interest of justice. Further, in the impugned order, the Ld. Commissioner (Appeal) recorded the finding that there is no finding given by the adjudicating authority for imposing the penalty under Section 117 of the Act. In that circumstances, the Ld. Commissioner(Appeal) has rightly dropped the penalty against the respondent. - AT
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