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 levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
Penalty levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
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