Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject the submissions of the ld. AR of the assessee that the issue of corporate guarantee by the assessee to its AEs is not an international transaction and direct the AO/TPO to decide the issue - AT
TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject the submissions of the ld. AR of the assessee that the issue of corporate guarantee by the assessee to its AEs is not an international transaction and direct the AO/TPO to decide the issue - AT
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