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 u/s 271AAB - Addition u/s 69B - income shown suo-motto - additional income brought to tax by the Assessing Officer - none of the conditions for levy of penalty at the lower rate of 10%, under clause (a) of Section 271AAB (1), are satisfied. Accordingly, it is held that in respect of such additional income, penalty is leviable at 30% under clause (a) of Section 271AAB(1). - AT
Penalty u/s 271AAB - Addition u/s 69B - income shown suo-motto - additional income brought to tax by the Assessing Officer - none of the conditions for levy of penalty at the lower rate of 10%, under clause (a) of Section 271AAB (1), are satisfied. Accordingly, it is held that in respect of such additional income, penalty is leviable at 30% under clause (a) of Section 271AAB(1). - AT
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