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...
Penalty for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
Penalty for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
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