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...
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
A bona fide deduction claim under section 80P(2)(a)(i), previously accepted in scrutiny assessment and rectification proceedings, was not treated as under-reported income in the stated circumstances. The notes state that section 270A(1) uses "may", requiring consideration of the full circumstances rather than automatic penalty. They further state that a penalty notice and order referring only generally to section 270A, without specifying the applicable sub-clause or limb, cannot sustain the penalty. The reported conclusion is that the penalty for under-reporting was deleted.
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