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 levied by the Assessing Officer solely based on the order of the Income Tax Settlement Commission withdrawing immunity from penalty and prosecution, without adhering to the due process prescribed under the Act. The Assessing Officer failed to make reference to assessment proceedings, record satisfaction regarding concealment of income or furnishing inaccurate particulars, and issue notice u/s 274 before initiating penalty proceedings. The penalty proceedings u/s 271(1)(c) were arbitrary, not in accordance with law, and void ab initio. Regarding penalty u/s 271AAA, the Assessing Officer did not refer to the conditions prescribed, statement recorded u/s 132(4), or opportunity given to the assessee to explain the undisclosed income. Consequently, the initiation of penalty proceedings u/s 271AAA was illegal, and the penalties levied u/s 271AAA were quashed.
Penalty u/s 271(1)(c) was levied by the Assessing Officer solely based on the order of the Income Tax Settlement Commission withdrawing immunity from penalty and prosecution, without adhering to the due process prescribed under the Act. The Assessing Officer failed to make reference to assessment proceedings, record satisfaction regarding concealment of income or furnishing inaccurate particulars, and issue notice u/s 274 before initiating penalty proceedings. The penalty proceedings u/s 271(1)(c) were arbitrary, not in accordance with law, and void ab initio. Regarding penalty u/s 271AAA, the Assessing Officer did not refer to the conditions prescribed, statement recorded u/s 132(4), or opportunity given to the assessee to explain the undisclosed income. Consequently, the initiation of penalty proceedings u/s 271AAA was illegal, and the penalties levied u/s 271AAA were quashed.
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