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 Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
The Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
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