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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Cash-transaction restrictions under sections 269SS and 271D are discussed in relation to receipts from registered immovable-property sale transactions. The notes state that penalty may not be warranted where cash receipts are from genuine, identifiable parties, are recorded as stock-in-trade, and are supported by registered sale deeds. They describe the restriction's purpose as curbing black-money generation rather than penalising bona fide transactions, and identify proof of genuineness and bona fides as material to relief from penalty.
Cash-transaction restrictions under sections 269SS and 271D are discussed in relation to receipts from registered immovable-property sale transactions. The notes state that penalty may not be warranted where cash receipts are from genuine, identifiable parties, are recorded as stock-in-trade, and are supported by registered sale deeds. They describe the restriction's purpose as curbing black-money generation rather than penalising bona fide transactions, and identify proof of genuineness and bona fides as material to relief from penalty.
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