Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to fact that the reward or profit to the AE is almost negligible, i.e. the ultimate profit is not even 1%, the adjustment if at all would also be negligible on the facts of the present case. - No transfer pricing adjustment can be made on account of corporate guarantee - AT
TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to fact that the reward or profit to the AE is almost negligible, i.e. the ultimate profit is not even 1%, the adjustment if at all would also be negligible on the facts of the present case. - No transfer pricing adjustment can be made on account of corporate guarantee - AT
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