Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Penalty u/s 271G - under TNMM adopted by the assessee, the profit of the international transaction has to be furnished, whereas the assessee has only furnished the entity level margins which consists of overall profits on AE and significant non non-AE transactions - reasonable cause for non-compliance - In the interest of justice, we vacate the order of learned CIT(A) and set aside the issue to the learned CIT(A). - AT
Penalty u/s 271G - under TNMM adopted by the assessee, the profit of the international transaction has to be furnished, whereas the assessee has only furnished the entity level margins which consists of overall profits on AE and significant non non-AE transactions - reasonable cause for non-compliance - In the interest of justice, we vacate the order of learned CIT(A) and set aside the issue to the learned CIT(A). - AT
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