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...
Maintainability of appeal - extended period of limitation - the only allegation in SCN for invocation of extended period of limitation is that the afore-mentioned omissions came to light in the course of audit, but for which tax would have escaped. It is found that such allegations do not stand, as admittedly appellant have deposited the tax and accepted the audit objection, prior to issue of SCN. - AT
Maintainability of appeal - extended period of limitation - the only allegation in SCN for invocation of extended period of limitation is that the afore-mentioned omissions came to light in the course of audit, but for which tax would have escaped. It is found that such allegations do not stand, as admittedly appellant have deposited the tax and accepted the audit objection, prior to issue of SCN. - AT
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