Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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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