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...
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Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
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