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...
Quashing of the penalty for undisclosed income removed the foundational finding of wilful tax evasion required to continue prosecution for an offence under section 276C(1)(i). Following a coordinate-bench ruling, the High Court treated the Tribunal's penalty order as effective because it had not been stayed; the Department's pending appeal did not justify continuation of criminal proceedings. The prosecution was quashed, while preserving the Department's liberty to seek revival and recall if the Tribunal's order is reversed in the pending appeal.
Quashing of the penalty for undisclosed income removed the foundational finding of wilful tax evasion required to continue prosecution for an offence under section 276C(1)(i). Following a coordinate-bench ruling, the High Court treated the Tribunal's penalty order as effective because it had not been stayed; the Department's pending appeal did not justify continuation of criminal proceedings. The prosecution was quashed, while preserving the Department's liberty to seek revival and recall if the Tribunal's order is reversed in the pending appeal.
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