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 under-reporting or misreporting of income under section 270A requires clear identification and communication of the applicable circumstance of under-reporting and, where relevant, the act constituting misreporting. Failure to specify these statutory grounds in the assessment order, notice or penalty order denies the taxpayer an effective opportunity to respond and breaches natural justice. Where the charge finally used to impose penalty differs from the charge initially invoked, the penalty proceedings are invalid. The section 270A penalty was therefore quashed as bad in law.
Penalty for under-reporting or misreporting of income under section 270A requires clear identification and communication of the applicable circumstance of under-reporting and, where relevant, the act constituting misreporting. Failure to specify these statutory grounds in the assessment order, notice or penalty order denies the taxpayer an effective opportunity to respond and breaches natural justice. Where the charge finally used to impose penalty differs from the charge initially invoked, the penalty proceedings are invalid. The section 270A penalty was therefore quashed as bad in law.
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