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 - Applicability of ration of decision made in the case of co-noticee - in absence of the appeal by revenue against this order the order has acquired finality and Commissioner cannot have passed any order beyond the order passed by his predecessor. In view of this fact, the Commissioner order imposing penalty on Shri JS cannot be sustained and the penalty imposed on Shri SS cannot be in excess of the penalty imposed by this order. - AT
Levy of penalty - Applicability of ration of decision made in the case of co-noticee - in absence of the appeal by revenue against this order the order has acquired finality and Commissioner cannot have passed any order beyond the order passed by his predecessor. In view of this fact, the Commissioner order imposing penalty on Shri JS cannot be sustained and the penalty imposed on Shri SS cannot be in excess of the penalty imposed by this order. - AT
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