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...
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
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