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...
No doubt the discretion to levy the penalty or to drop the penalty proceedings is entirely the discretion of the appropriate authority who is authorized under the statute, however, where in case of same bank, different approach is adopted by the same authority in exercise of its powers so bestowed by the statutory, the same reflect arbitrariness in absence of any distinguishing facts and circumstances so highlighted and any such arbitrary levy of penalty reflects non-application of mind by such authority and penalty so levied is liable to be deleted.
No doubt the discretion to levy the penalty or to drop the penalty proceedings is entirely the discretion of the appropriate authority who is authorized under the statute, however, where in case of same bank, different approach is adopted by the same authority in exercise of its powers so bestowed by the statutory, the same reflect arbitrariness in absence of any distinguishing facts and circumstances so highlighted and any such arbitrary levy of penalty reflects non-application of mind by such authority and penalty so levied is liable to be deleted.
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