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)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
Penalty u/s. 271(1)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
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