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...
ITAT adjudicated a tax dispute regarding penalty u/s 271(1)(c), finding no justification for penalty imposition. The tribunal determined that returned income matched assessed income, and no substantive evidence of income concealment existed. The show cause notice lacked specific allegations of tax evasion or inaccurate income particulars. Given the absence of procedural fairness and no demonstrable intent to evade tax, the tribunal deleted the 100% penalty. The decision hinged on procedural defects and lack of clear evidence of deliberate tax non-compliance, ultimately ruling in favor of the assessee based on principles of natural justice and procedural propriety.
ITAT adjudicated a tax dispute regarding penalty u/s 271(1)(c), finding no justification for penalty imposition. The tribunal determined that returned income matched assessed income, and no substantive evidence of income concealment existed. The show cause notice lacked specific allegations of tax evasion or inaccurate income particulars. Given the absence of procedural fairness and no demonstrable intent to evade tax, the tribunal deleted the 100% penalty. The decision hinged on procedural defects and lack of clear evidence of deliberate tax non-compliance, ultimately ruling in favor of the assessee based on principles of natural justice and procedural propriety.
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