Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Penalty imposed u/s 221(1) r.w.s. 140A(3) - non-payment of self-assessment tax - Return of Income as filed u/s 139(1) itself was declared an invalid Return - scope of Sec.140A(3) - without there being any requisite corresponding amendment to Sec. 221 of the Act in consonance with the amendments carried out in Sec. 140A(3) of the Act w.e.f. 01.04.1989, the Assessing Officer erred in levying the impugned penalty.
Penalty imposed u/s 221(1) r.w.s. 140A(3) - non-payment of self-assessment tax - Return of Income as filed u/s 139(1) itself was declared an invalid Return - scope of Sec.140A(3) - without there being any requisite corresponding amendment to Sec. 221 of the Act in consonance with the amendments carried out in Sec. 140A(3) of the Act w.e.f. 01.04.1989, the Assessing Officer erred in levying the impugned penalty.
Note: It is a system-generated summary and is for quick reference only.