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...
Penalty u/s 271B - the books of account of the Assessee have also been audited only on 30.09.2011, however it seems that somehow due to inadvertent or otherwise mistake in the name of Auditor, the Assessee failed to file correct audited books of account, alongwith original return of income, but it is a fact that audited books of account which are not in dispute, have duly been filed along with the revised return of income. - No penalty - AT
Penalty u/s 271B - the books of account of the Assessee have also been audited only on 30.09.2011, however it seems that somehow due to inadvertent or otherwise mistake in the name of Auditor, the Assessee failed to file correct audited books of account, alongwith original return of income, but it is a fact that audited books of account which are not in dispute, have duly been filed along with the revised return of income. - No penalty - AT
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