Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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