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) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
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