Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
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Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
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