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 misreporting under section 270A(9) requires a notice identifying the precise statutory instance alleged, because each form of misreporting calls for a distinct explanation. An assessment for the year preceding a search must follow the prescribed reassessment procedure, and an invalid assessment may be challenged in penalty proceedings where it forms the penalty's foundation. Voluntary disclosure of additional professional income, even if accepted in assessment, does not by itself establish misreporting. Section 271AAD addresses false entries or omissions linked to fraudulent input tax credit arrangements and does not extend merely to unrecorded professional receipts represented by cash found in search.
Penalty for misreporting under section 270A(9) requires a notice identifying the precise statutory instance alleged, because each form of misreporting calls for a distinct explanation. An assessment for the year preceding a search must follow the prescribed reassessment procedure, and an invalid assessment may be challenged in penalty proceedings where it forms the penalty's foundation. Voluntary disclosure of additional professional income, even if accepted in assessment, does not by itself establish misreporting. Section 271AAD addresses false entries or omissions linked to fraudulent input tax credit arrangements and does not extend merely to unrecorded professional receipts represented by cash found in search.
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