Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Penalty u/s 272A(2)(c) - Non-issuance of TDS certificate in time - assessee was under bonafide belief that once the tax has not been deposited to the Government account then no certificate under section 203 could have been issued and such a bonafide belief falls within the ambit of section 273B, which envisages that no penalty is leviable if the assessee has bonafide reasons. - AT
Penalty u/s 272A(2)(c) - Non-issuance of TDS certificate in time - assessee was under bonafide belief that once the tax has not been deposited to the Government account then no certificate under section 203 could have been issued and such a bonafide belief falls within the ambit of section 273B, which envisages that no penalty is leviable if the assessee has bonafide reasons. - AT
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