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 270A(2)(b) was deleted where executors could not file the deceased assessee's return before probate was granted. The Tribunal accepted that, under section 270A(6), the explanation was reasonable and bona fide because the delay arose from circumstances beyond the executors' control, including the absence of court appointment and the time taken to obtain probate. It also noted that the obligation on legal heirs or executors to file the return arises only after receipt of the court order appointing them, and the relevant period was covered by the Supreme Court's COVID-related limitation extension. The penalty was therefore unsustainable.
Penalty under section 270A(2)(b) was deleted where executors could not file the deceased assessee's return before probate was granted. The Tribunal accepted that, under section 270A(6), the explanation was reasonable and bona fide because the delay arose from circumstances beyond the executors' control, including the absence of court appointment and the time taken to obtain probate. It also noted that the obligation on legal heirs or executors to file the return arises only after receipt of the court order appointing them, and the relevant period was covered by the Supreme Court's COVID-related limitation extension. The penalty was therefore unsustainable.
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