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...
Levying penalty u/s. 272A(2)(k) - Filing the return belatedly - There may have been procedural lapse on the part of the assessee however, due to such procedural lapse no prejudice has been caused to the Revenue. This fact has also been admitted by the Ld. DR. - The provisions of Section 272A(2)(k) are subject to provisions of section 273B of the Act and hence, the relevance of reasonable cause has to be established. - AT
Levying penalty u/s. 272A(2)(k) - Filing the return belatedly - There may have been procedural lapse on the part of the assessee however, due to such procedural lapse no prejudice has been caused to the Revenue. This fact has also been admitted by the Ld. DR. - The provisions of Section 272A(2)(k) are subject to provisions of section 273B of the Act and hence, the relevance of reasonable cause has to be established. - AT
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