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...
Immunity from penalty for under-reporting of income requires reconsideration where a timely Form No. 68 application is followed by rectification of the assessment demand resulting in a refund. The material states that neither the penalty order nor the appellate order considered whether the rectification affected compliance with the requirement to pay tax and interest, particularly where no demand ultimately survived. The immunity claim was restored for fresh examination by a speaking order after granting reasonable opportunity, with consequential reconsideration of the penalty issue if required.
Immunity from penalty for under-reporting of income requires reconsideration where a timely Form No. 68 application is followed by rectification of the assessment demand resulting in a refund. The material states that neither the penalty order nor the appellate order considered whether the rectification affected compliance with the requirement to pay tax and interest, particularly where no demand ultimately survived. The immunity claim was restored for fresh examination by a speaking order after granting reasonable opportunity, with consequential reconsideration of the penalty issue if required.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4778
Join Channel
TaxTMI 
