Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Penalty u/s 271AAB - disclosure of income in his statement u/s 132(4) - Unless and until income offered to tax by an assessee comes within the mischief of undisclosed income and that too of the specified previous year it is not open for the AO to invoke provisions of Section 271AAB - if penalty was mandatory and automatic then the right of appeal u/s 246A would not have been provided
Penalty u/s 271AAB - disclosure of income in his statement u/s 132(4) - Unless and until income offered to tax by an assessee comes within the mischief of undisclosed income and that too of the specified previous year it is not open for the AO to invoke provisions of Section 271AAB - if penalty was mandatory and automatic then the right of appeal u/s 246A would not have been provided
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