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 271(1)(b) - failure to sign on the so called "Consent Letter" which is not an authorized form notified by the Government - In the context of section 273B of the Act, the expression "reasonable cause" has been explained to mean a cause which prevents a man of ordinary prudence and average intelligence, acting under normal circumstances, without negligence or inaction or want of bona fide. - Levy of penalty deleted - AT
Penalty u/s 271(1)(b) - failure to sign on the so called "Consent Letter" which is not an authorized form notified by the Government - In the context of section 273B of the Act, the expression "reasonable cause" has been explained to mean a cause which prevents a man of ordinary prudence and average intelligence, acting under normal circumstances, without negligence or inaction or want of bona fide. - Levy of penalty deleted - AT
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