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...
The case involved the entitlement to exemption u/s 11/12 based on the filing of an audit report. Non-filing of the audit report with the return of income was considered a procedural irregularity, not a basis for denying the exemption. The CBDT Circular allowed for condoning delays, but as no condonation petition was filed, this point was rejected. The assessee was advised to appeal against the intimation u/s 143(1) rather than a rectification order u/s 154. The decision emphasized that the correct amount of tax should be imposed on the assessee, even if the appeal channel was not chosen correctly. Ultimately, the assessee was granted the benefit of exemption u/s 11/12 despite the delay in filing the audit report.
The case involved the entitlement to exemption u/s 11/12 based on the filing of an audit report. Non-filing of the audit report with the return of income was considered a procedural irregularity, not a basis for denying the exemption. The CBDT Circular allowed for condoning delays, but as no condonation petition was filed, this point was rejected. The assessee was advised to appeal against the intimation u/s 143(1) rather than a rectification order u/s 154. The decision emphasized that the correct amount of tax should be imposed on the assessee, even if the appeal channel was not chosen correctly. Ultimately, the assessee was granted the benefit of exemption u/s 11/12 despite the delay in filing the audit report.
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