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 271AAB(1A)(b) was levied for suo moto disallowance of personal expenses u/s 37 by the assessee in the return filed in response to a notice u/s 153A. The assessee had made the disallowance in the search assessment completed u/s 153A, where no concealment was found. The issue of levying penalty u/s 271AAB in such circumstances is no longer res integra, following the Delhi High Court's decision in Neeraj Jindal. Accordingly, the penalty u/s 271AAB is deleted.
Penalty u/s 271AAB(1A)(b) was levied for suo moto disallowance of personal expenses u/s 37 by the assessee in the return filed in response to a notice u/s 153A. The assessee had made the disallowance in the search assessment completed u/s 153A, where no concealment was found. The issue of levying penalty u/s 271AAB in such circumstances is no longer res integra, following the Delhi High Court's decision in Neeraj Jindal. Accordingly, the penalty u/s 271AAB is deleted.
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