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) - return filed disclosing higher income u/s 153A - no incriminating material found - when the Revenue could not lay hands on any tangible material except conditional and tacit averments, which confession in itself is seen to be non-admission of any ingenuity - no hesitation to hold that such confession u/s 139(4) cannot be the basis for imposition of onerous penalty
Penalty u/s 271(1)(c) - return filed disclosing higher income u/s 153A - no incriminating material found - when the Revenue could not lay hands on any tangible material except conditional and tacit averments, which confession in itself is seen to be non-admission of any ingenuity - no hesitation to hold that such confession u/s 139(4) cannot be the basis for imposition of onerous penalty
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