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) - The Appellate Tribunal observed that the appellant, during reassessment proceedings, had filed their return of income but failed to provide sufficient documentation to substantiate claimed expenses. Notably, the assessing officer disallowed 50% of the claimed expenses, but did not specifically charge the appellant with concealing income or furnishing inaccurate particulars in the assessment order. In the subsequent penalty order, the assessing officer invoked twin charges without clear evidence to support them. Considering the lack of specific charges and evidence, the Tribunal directed the assessing officer to delete the penalty.
Penalty u/s 271(1)(c) - The Appellate Tribunal observed that the appellant, during reassessment proceedings, had filed their return of income but failed to provide sufficient documentation to substantiate claimed expenses. Notably, the assessing officer disallowed 50% of the claimed expenses, but did not specifically charge the appellant with concealing income or furnishing inaccurate particulars in the assessment order. In the subsequent penalty order, the assessing officer invoked twin charges without clear evidence to support them. Considering the lack of specific charges and evidence, the Tribunal directed the assessing officer to delete the penalty.
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