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 276CC contains a statutory exception to prosecution for failure to furnish an income-tax return where tax payable on regular assessment, after reducing advance tax and tax deducted at source, does not exceed the prescribed threshold. The notes state that an accepted return showing a refund entitlement after TDS credit indicates no revenue loss and may bring the taxpayer within that exception. They further note that failure by the sanctioning authority to consider TDS can render prosecution unwarranted and an abuse of process, supporting quashing of the complaint.
Section 276CC contains a statutory exception to prosecution for failure to furnish an income-tax return where tax payable on regular assessment, after reducing advance tax and tax deducted at source, does not exceed the prescribed threshold. The notes state that an accepted return showing a refund entitlement after TDS credit indicates no revenue loss and may bring the taxpayer within that exception. They further note that failure by the sanctioning authority to consider TDS can render prosecution unwarranted and an abuse of process, supporting quashing of the complaint.
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