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...
Non-compliance with notices under section 142(1) did not justify penalty under section 272A(1)(d) where the assessee later furnished detailed replies with supporting material, the Assessing Officer verified and accepted that material, and the assessment was completed under section 143(3). The Tribunal treated the earlier default as merged in the subsequent compliance and as deemed condoned by the regular assessment, so the penalty was held not leviable and was deleted in the lead matter and connected appeals.
Non-compliance with notices under section 142(1) did not justify penalty under section 272A(1)(d) where the assessee later furnished detailed replies with supporting material, the Assessing Officer verified and accepted that material, and the assessment was completed under section 143(3). The Tribunal treated the earlier default as merged in the subsequent compliance and as deemed condoned by the regular assessment, so the penalty was held not leviable and was deleted in the lead matter and connected appeals.
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