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 was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
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