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) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
Penalty u/s 271(1)(c) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
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