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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Section 43 penalty under the Black Money Act was held unsustainable where the foreign investment was disclosed in the audited balance sheet and in Part A-BS of the return, even though Schedule FA was left blank. The Tribunal held that the statutory trigger is failure to furnish information in the return of income, and that this requirement was met because the return was not silent on the foreign asset. A CBDT circular or FAQ could not widen the penalty provision. In the absence of any allegation that the investment was unexplained, unaccounted, or sourced from undisclosed foreign income, the omission was treated as a technical reporting lapse. The CIT(A)'s deletion of penalty was affirmed.
Section 43 penalty under the Black Money Act was held unsustainable where the foreign investment was disclosed in the audited balance sheet and in Part A-BS of the return, even though Schedule FA was left blank. The Tribunal held that the statutory trigger is failure to furnish information in the return of income, and that this requirement was met because the return was not silent on the foreign asset. A CBDT circular or FAQ could not widen the penalty provision. In the absence of any allegation that the investment was unexplained, unaccounted, or sourced from undisclosed foreign income, the omission was treated as a technical reporting lapse. The CIT(A)'s deletion of penalty was affirmed.
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