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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A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
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