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 notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
Penalty notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
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