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...
Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
Penalties for alleged violations of cash loan and repayment restrictions were treated as consequential to the quantum assessments in which the underlying findings were recorded. Once the co-ordinate Bench had quashed the assessee's quantum assessments, the foundation for the penalty orders disappeared, and the penalties had no independent existence to survive. The Tribunal therefore deleted all the penalties for the years in appeal and rejected the request to keep the matters pending, while leaving the Department free to seek revival if it later succeeded in the quantum proceedings.
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