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 under section 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
Penalty under section 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
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