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. 271B - failure to get his books audited and furnish Audit Report u/s. 44AB - Section 271B as extracted above further throws light on the legislative intent as it specifically provides that no penalty "shall’ be imposed if the assessee proves "that there was reasonable cause for the said failure". - the explanations offered by the assessee have been ignored by the AO and CIT(A) - Penalty deleted - AT
Levy of penalty u/s. 271B - failure to get his books audited and furnish Audit Report u/s. 44AB - Section 271B as extracted above further throws light on the legislative intent as it specifically provides that no penalty "shall’ be imposed if the assessee proves "that there was reasonable cause for the said failure". - the explanations offered by the assessee have been ignored by the AO and CIT(A) - Penalty deleted - AT
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