Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Levy of penalty u/s 271(1)(c) - suo moto disclosure of income before detection by the AO - It is the settled law that the belated return cannot be revised under the provisions of section 139(5) of the Act. In view of the above we hold that there was no possibility for the assessee to revise the return of income - No penalty - AT
Levy of penalty u/s 271(1)(c) - suo moto disclosure of income before detection by the AO - It is the settled law that the belated return cannot be revised under the provisions of section 139(5) of the Act. In view of the above we hold that there was no possibility for the assessee to revise the return of income - No penalty - AT
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