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 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
Levy of penalty u/s 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
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