X Ltd., operating in India, is the dealer for the goods manufactured by Yen Ltd. of Japan. Yen Lid. owns 55% shares of X Ltd. and out of 7 directors of the company, 4 were appointed by them. The Assessing Officer, after verification of international transactions of 300 lakhs of XLtd. for the relevant year and by noticing that the company had failed to maintain the requisite records and had also not obtained the accountants report, adjusted its income by making an addition of 30,00,000 to the declared income and also issued a show cause notice to levy various penalties. X Ltd seeks your expert opinion