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 assessee was penalized u/s 271(1)(c) for addition of sale consideration due to lack of vouchers. The CIT(A) partly confirmed the addition for want of vouchers. The assessee argued that no penalty is maintainable as the transaction was truly disclosed, and long-term capital gains were reported. The ITAT held that the CIT(A) restricted the addition after examining the evidence, indicating the assessee succeeded partially. The AO imposed the penalty solely for non-submission of supporting vouchers. Relying on the CAFCO SYNDICATE SHIPPING CO. case, the ITAT ruled that penalty cannot be imposed for non-furnishing evidence as it does not amount to concealment of income. Consequently, the penalty levied by the AO was deleted, and the assessee's grounds were allowed.
The assessee was penalized u/s 271(1)(c) for addition of sale consideration due to lack of vouchers. The CIT(A) partly confirmed the addition for want of vouchers. The assessee argued that no penalty is maintainable as the transaction was truly disclosed, and long-term capital gains were reported. The ITAT held that the CIT(A) restricted the addition after examining the evidence, indicating the assessee succeeded partially. The AO imposed the penalty solely for non-submission of supporting vouchers. Relying on the CAFCO SYNDICATE SHIPPING CO. case, the ITAT ruled that penalty cannot be imposed for non-furnishing evidence as it does not amount to concealment of income. Consequently, the penalty levied by the AO was deleted, and the assessee's grounds were allowed.
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