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 271(1)(c) - addition was confirmed by CIT(A) and ITAT, Thus, there is no dispute with regard to the concealment of income and furnishing of inaccurate particulars of income - If there is no variance between the charge levied at the time of initiation of penalty proceedings and the charge levied at the time of imposition of penalty then no fault can be found with regard to defect in notice so as to hold that the penalty is not leviable
Penalty U/s 271(1)(c) - addition was confirmed by CIT(A) and ITAT, Thus, there is no dispute with regard to the concealment of income and furnishing of inaccurate particulars of income - If there is no variance between the charge levied at the time of initiation of penalty proceedings and the charge levied at the time of imposition of penalty then no fault can be found with regard to defect in notice so as to hold that the penalty is not leviable
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