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 deleted the penalty levied u/s 271(1)(b) for non-compliance with a notice issued u/s 142(1) during reassessment proceedings. Considering the extraordinary circumstances of the Covid-19 pandemic, lockdowns, and the suffering caused, the Tribunal held that the department should have taken a liberal view in condoning the default. The assessee's non-compliance was covered u/s 273B, read with Section 271(1)(b), as Section 271(1)(b) is subject to Section 273B. The assessee's appeal was allowed, and the penalty was deleted.
The Income Tax Appellate Tribunal deleted the penalty levied u/s 271(1)(b) for non-compliance with a notice issued u/s 142(1) during reassessment proceedings. Considering the extraordinary circumstances of the Covid-19 pandemic, lockdowns, and the suffering caused, the Tribunal held that the department should have taken a liberal view in condoning the default. The assessee's non-compliance was covered u/s 273B, read with Section 271(1)(b), as Section 271(1)(b) is subject to Section 273B. The assessee's appeal was allowed, and the penalty was deleted.
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