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...
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
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