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...
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Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
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