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...
Validity of penalty levied u/s 271(1)(b) - non-compliance - The assessee has shown sufficient cause for non-compliance, moreover, such non-compliance was done by granting adjournment by the AO himself. - the assessment was framed u/s 143(3) - the penalty u/s 271(1)(b) of the Act cannot be imposed on the assessee for such bonafide default due to reasons beyond his control - AT
Validity of penalty levied u/s 271(1)(b) - non-compliance - The assessee has shown sufficient cause for non-compliance, moreover, such non-compliance was done by granting adjournment by the AO himself. - the assessment was framed u/s 143(3) - the penalty u/s 271(1)(b) of the Act cannot be imposed on the assessee for such bonafide default due to reasons beyond his control - AT
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