Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Penalty u/s 271(1)(c) - accepted quantum addition - in penalty proceedings he offer explanation that the jewellery found during search were already offered to tax in the VDIS, 1997 - quantum assessment as well as the penalty proceedings are independent of each other - the explanation offered should be tested for its correctness and only if it is found to be palpably false or not acceptable, then the question of imposing the penalty would arise.
Penalty u/s 271(1)(c) - accepted quantum addition - in penalty proceedings he offer explanation that the jewellery found during search were already offered to tax in the VDIS, 1997 - quantum assessment as well as the penalty proceedings are independent of each other - the explanation offered should be tested for its correctness and only if it is found to be palpably false or not acceptable, then the question of imposing the penalty would arise.
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