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 272A(1)(C) - Failure to comply to the summon issued u/s 131(1) - AO has rightly acted as per the provision of sub-Section 3 of Section 272A of the Act by making a reference to Joint Commissioner of Income Tax for initiation of penalty and the same was levied at Rs. 10,000/- u/s 272A(1)(C) of the Act. The ground of the assessee that notice of demand u/s 156 of the Act should be under the signature of the ld. AO and not Joint Commissioner of Income Tax has no merit because the issue before us is the penalty levied u/s 272A(1)(C) of the Act. - AT
Levy of penalty u/s 272A(1)(C) - Failure to comply to the summon issued u/s 131(1) - AO has rightly acted as per the provision of sub-Section 3 of Section 272A of the Act by making a reference to Joint Commissioner of Income Tax for initiation of penalty and the same was levied at Rs. 10,000/- u/s 272A(1)(C) of the Act. The ground of the assessee that notice of demand u/s 156 of the Act should be under the signature of the ld. AO and not Joint Commissioner of Income Tax has no merit because the issue before us is the penalty levied u/s 272A(1)(C) of the Act. - AT
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