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...
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
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