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 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
Penalty under section 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
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