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 levied u/s. 271G - nternational transactions - assessee ignoring the provisions of Section 92D of the Act as well as Rule 10D of the Income Tax Rules - Section 273B of the Act provides for reasonable cause and if that is justified, penalty/s. 271G of the Act may not be imposed and when this opportunity is given to the assessee by the statutes itself and the assessee has explained the reasonable causes which was accepted by the Ld. CIT(Appeal) and after perusing such reasons, we are in conformity with the findings of the Ld. CIT(Appeals). - AT
Penalty levied u/s. 271G - nternational transactions - assessee ignoring the provisions of Section 92D of the Act as well as Rule 10D of the Income Tax Rules - Section 273B of the Act provides for reasonable cause and if that is justified, penalty/s. 271G of the Act may not be imposed and when this opportunity is given to the assessee by the statutes itself and the assessee has explained the reasonable causes which was accepted by the Ld. CIT(Appeal) and after perusing such reasons, we are in conformity with the findings of the Ld. CIT(Appeals). - AT
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