Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the assessee had with the AE’s to be also at Arm’s Length Price and therefore no adjustment was warranted in the facts and circumstances of the case. - AT
TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the assessee had with the AE’s to be also at Arm’s Length Price and therefore no adjustment was warranted in the facts and circumstances of the case. - AT
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