Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Provisional attachment fails without material showing likely concealment, transfer, or dealing that could frustrate confiscation of mortgaged property...
Works-contract goods transfers remain outside service tax, while qualifying lift irrigation works receive exemption and extended limitation cannot app...
Penalty for misreporting under section 270A requires the revenue to identify and establish a statutory instance of misreporting. Transfer-pricing adjustments arising solely from rejection of the taxpayer's benchmarking methodology, economic or comparability analysis, and adoption of a different most appropriate method do not by themselves establish misreporting. Reporting international transactions in Form 3CEB and maintaining prescribed transfer-pricing documentation support the position that the transactions were disclosed. Where no failure to report an international transaction or other statutory misreporting circumstance is identified, the adjustment falls within the exclusion for eligible transfer-pricing adjustments and cannot attract misreporting penalty.
Penalty for misreporting under section 270A requires the revenue to identify and establish a statutory instance of misreporting. Transfer-pricing adjustments arising solely from rejection of the taxpayer's benchmarking methodology, economic or comparability analysis, and adoption of a different most appropriate method do not by themselves establish misreporting. Reporting international transactions in Form 3CEB and maintaining prescribed transfer-pricing documentation support the position that the transactions were disclosed. Where no failure to report an international transaction or other statutory misreporting circumstance is identified, the adjustment falls within the exclusion for eligible transfer-pricing adjustments and cannot attract misreporting penalty.
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