Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Penalty u/s 271G - assessee was unable to submit internal TNMM by working out the profitability of AE and non-AE segment - due to peculiar nature of the product and constant mixing and re-mixing of diamonds obtained from AEs and non-AEs, it would not be feasible to maintain records to determine segmental profitability to work out internal TNMM. - No penalty.
Penalty u/s 271G - assessee was unable to submit internal TNMM by working out the profitability of AE and non-AE segment - due to peculiar nature of the product and constant mixing and re-mixing of diamonds obtained from AEs and non-AEs, it would not be feasible to maintain records to determine segmental profitability to work out internal TNMM. - No penalty.
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