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) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
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