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 levied u/s 270A - misreporting of income un/s 270A(8) and 270A(9) or not - Assessee filed the ITR after search conducted on third party but before the due date of filing of ITR - Since the return of income was not due as on the date of search carried out on 10.08.2016 and the accounting year was not ended also therefore the books of accounts were not up-dated. Therefore, the assessee's case does not fall under the category of misreporting of income. - No penalty - HC
Penalty levied u/s 270A - misreporting of income un/s 270A(8) and 270A(9) or not - Assessee filed the ITR after search conducted on third party but before the due date of filing of ITR - Since the return of income was not due as on the date of search carried out on 10.08.2016 and the accounting year was not ended also therefore the books of accounts were not up-dated. Therefore, the assessee's case does not fall under the category of misreporting of income. - No penalty - HC
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