Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
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