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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Journal-entry transfers of outstanding loans during restructuring of related concerns may constitute reasonable cause for non-compliance with the prescribed mode of loan acceptance where the original loans were received through banking channels, no cash movement occurred, and the transactions are genuine. The notes explain that journal entries are a recognised method of recording business transactions and that penalty protection may apply if there is no adverse finding of non-business use or movement of money. On the stated facts, transfer of genuine loans through journal entries to support a business takeover and financial transition was treated as supported by reasonable cause, resulting in deletion of the remaining penalty.
Journal-entry transfers of outstanding loans during restructuring of related concerns may constitute reasonable cause for non-compliance with the prescribed mode of loan acceptance where the original loans were received through banking channels, no cash movement occurred, and the transactions are genuine. The notes explain that journal entries are a recognised method of recording business transactions and that penalty protection may apply if there is no adverse finding of non-business use or movement of money. On the stated facts, transfer of genuine loans through journal entries to support a business takeover and financial transition was treated as supported by reasonable cause, resulting in deletion of the remaining penalty.
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