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...
Section 273B provides that penalty for belated furnishing of a tax audit report under section 271B is not automatic where the taxpayer establishes reasonable cause. The explanation must be considered judicially to determine whether the default occurred without reasonable cause. The notes identify prior auditor negligence and a consequent change of auditor as reasonable cause where accounts were maintained, the audit was obtained, and the report was furnished before assessment concluded. A technical and venial lapse, without deliberate or wilful default or revenue loss, supports deletion of the penalty.
Section 273B provides that penalty for belated furnishing of a tax audit report under section 271B is not automatic where the taxpayer establishes reasonable cause. The explanation must be considered judicially to determine whether the default occurred without reasonable cause. The notes identify prior auditor negligence and a consequent change of auditor as reasonable cause where accounts were maintained, the audit was obtained, and the report was furnished before assessment concluded. A technical and venial lapse, without deliberate or wilful default or revenue loss, supports deletion of the penalty.
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