Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
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