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...
Levy of penalty - mis-declaration of description of imported goods - Having found that the appellant had no intention, the Commissioner (Appeals) has still proceed to confirmed a reduced penalty under section 114AA upon the appellant - It is found that this cannot be sustained because once the intention is lacking, no penalty can be imposed upon the appellant under section 114AA. - AT
Levy of penalty - mis-declaration of description of imported goods - Having found that the appellant had no intention, the Commissioner (Appeals) has still proceed to confirmed a reduced penalty under section 114AA upon the appellant - It is found that this cannot be sustained because once the intention is lacking, no penalty can be imposed upon the appellant under section 114AA. - AT
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