Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Notice u/s 271AAB to levy penalty u/s 271(1)(c) - AO gets the jurisdiction to levy the penalty by issuing a notice and therefore, it is not a procedural requirement but is a jurisdictional one - two provisions operate in different circumstances and by issuance of notice u/s 271AAB AO cannot thereafter change it to section 271(1)(c) and levy penalty thereunder - no penalty
Notice u/s 271AAB to levy penalty u/s 271(1)(c) - AO gets the jurisdiction to levy the penalty by issuing a notice and therefore, it is not a procedural requirement but is a jurisdictional one - two provisions operate in different circumstances and by issuance of notice u/s 271AAB AO cannot thereafter change it to section 271(1)(c) and levy penalty thereunder - no penalty
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