Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Customs jurisdiction defined for Principal Commissioner, Vishakhapatnam, covering specified ports, districts and India's adjacent EEZ; effective on pu...
Penalty for failure to furnish transfer pricing documentation was deleted because the assessee had substantially complied by producing transfer pricing study reports, available segmental information and supporting documents, while the TPO accepted the benchmarking results and did not disturb the arm's length price. The alleged deficiency was only the absence of transaction-specific profitability in the form sought by the TPO, which was treated as a technical or venial breach. The Tribunal also accepted reasonable cause arising from the practical difficulty of precise AE and non-AE cost allocation in the diamond trade, and distinguished the contrary reliance on Shatrunjay Diamonds.
Penalty for failure to furnish transfer pricing documentation was deleted because the assessee had substantially complied by producing transfer pricing study reports, available segmental information and supporting documents, while the TPO accepted the benchmarking results and did not disturb the arm's length price. The alleged deficiency was only the absence of transaction-specific profitability in the form sought by the TPO, which was treated as a technical or venial breach. The Tribunal also accepted reasonable cause arising from the practical difficulty of precise AE and non-AE cost allocation in the diamond trade, and distinguished the contrary reliance on Shatrunjay Diamonds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
