Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Penalty u/s 271(1)(c) - There is no conclusive proof that the assessee has PE in India. In the penalty proceedings the AO simply relied on the MAP proceedings in holding that the assessee has PE in India which in fact is not correct. - there is no concealment of income or furnishing inaccurate particulars of such income by the assessee - No penalty - AT
Penalty u/s 271(1)(c) - There is no conclusive proof that the assessee has PE in India. In the penalty proceedings the AO simply relied on the MAP proceedings in holding that the assessee has PE in India which in fact is not correct. - there is no concealment of income or furnishing inaccurate particulars of such income by the assessee - No penalty - AT
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