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) - deduction u/s. 80GGC denied - second round of appeal - the Tribunal ruled in favor of the assessee, holding that the claim for deduction was made in good faith. They emphasized that the claim was based on the opinion of the auditor and was supported by genuine belief. Despite the deduction being ultimately disallowed, the authorities found that there was no intention to provide inaccurate particulars of income. Therefore, the penalty under section 271(1)(c) was deemed unjustified and was deleted.
Penalty u/s. 271(1)(c) - deduction u/s. 80GGC denied - second round of appeal - the Tribunal ruled in favor of the assessee, holding that the claim for deduction was made in good faith. They emphasized that the claim was based on the opinion of the auditor and was supported by genuine belief. Despite the deduction being ultimately disallowed, the authorities found that there was no intention to provide inaccurate particulars of income. Therefore, the penalty under section 271(1)(c) was deemed unjustified and was deleted.
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