Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
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