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 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
