Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Penalty u/s 271(1)(c) - Defective notice u/s 274 - non specification of charge - new plea before the authorities below - In this case in hand, there is no such plea raised by the assessee before the Assessing Officer at the initial stage. Hence, the notice issued under section 271(1)(c) of the Act is valid notice and therefore, the ground raised by the assessee is not acceptable. - AT
Penalty u/s 271(1)(c) - Defective notice u/s 274 - non specification of charge - new plea before the authorities below - In this case in hand, there is no such plea raised by the assessee before the Assessing Officer at the initial stage. Hence, the notice issued under section 271(1)(c) of the Act is valid notice and therefore, the ground raised by the assessee is not acceptable. - AT
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