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 held that penalty proceedings u/s 271AAB initiated in order u/s 143(3) became time-barred on 30.9.2017 as no substantive order was passed within statutory limitation period under section 275(1)(a). The Tribunal found the penalty notice defective for failing to specify precise grounds of concealment. Consequently, the penalty order levied on Rs. 1 crore addition was deleted. The assessee's appeal was allowed, effectively quashing the penalty proceedings due to procedural irregularities and limitation constraints in initiating and concluding penalty action.
ITAT held that penalty proceedings u/s 271AAB initiated in order u/s 143(3) became time-barred on 30.9.2017 as no substantive order was passed within statutory limitation period under section 275(1)(a). The Tribunal found the penalty notice defective for failing to specify precise grounds of concealment. Consequently, the penalty order levied on Rs. 1 crore addition was deleted. The assessee's appeal was allowed, effectively quashing the penalty proceedings due to procedural irregularities and limitation constraints in initiating and concluding penalty action.
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