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...
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
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