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 Income Tax Appellate Tribunal allowed the assessee's appeal and held that there was a reasonable cause for the failure to furnish the audit report as required u/s 44AB of the Income Tax Act. The accountant responsible for maintaining the firm's accounts had abruptly resigned before finalizing the accounts for the relevant year. Upon rejoining after being offered a revised salary, the accountant completed the accounts, which were subsequently audited and filed. The Tribunal considered the explanations offered by the assessee and found that the conduct demonstrated a reasonable cause for the failure as per Section 273B. The assessee had committed only a technical breach without any loss to the government's exchequer, as no additions were made during the assessment proceedings.
The Income Tax Appellate Tribunal allowed the assessee's appeal and held that there was a reasonable cause for the failure to furnish the audit report as required u/s 44AB of the Income Tax Act. The accountant responsible for maintaining the firm's accounts had abruptly resigned before finalizing the accounts for the relevant year. Upon rejoining after being offered a revised salary, the accountant completed the accounts, which were subsequently audited and filed. The Tribunal considered the explanations offered by the assessee and found that the conduct demonstrated a reasonable cause for the failure as per Section 273B. The assessee had committed only a technical breach without any loss to the government's exchequer, as no additions were made during the assessment proceedings.
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