Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Penalty u/s 271BA - non- filing of report as required u/s 92E - Once we hold that the assessee and the alleged AE could not be treated as associated enterprises, and there are no other alleged ‘international transactions’ on the facts of this case, it could not be said that the assessee had entered into any international transactions. As a corollary to this finding, the very foundation of impugned penalties ceases to hold good in law. - No penalty.
Penalty u/s 271BA - non- filing of report as required u/s 92E - Once we hold that the assessee and the alleged AE could not be treated as associated enterprises, and there are no other alleged ‘international transactions’ on the facts of this case, it could not be said that the assessee had entered into any international transactions. As a corollary to this finding, the very foundation of impugned penalties ceases to hold good in law. - No penalty.
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