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...
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
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