Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Since the AO made the disallowance only on the ground that Form 15G/15H were not submitted to the ld. Commissioner in time, only penalty proceedings can be initiated under section 272A(2)(f) and no disallowance can be made under section 40(a)(ia) - AT
Since the AO made the disallowance only on the ground that Form 15G/15H were not submitted to the ld. Commissioner in time, only penalty proceedings can be initiated under section 272A(2)(f) and no disallowance can be made under section 40(a)(ia) - AT
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