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 for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
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