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...
Penalty u/s 271D - period of limitation - CIT(A) took the date on which the one year period from the end of the financial year in which the notice was issued as 31/03/2022. - We are unable to understand where from this date has come. Expiry of one year is not relatable to this date either from the date of the assessment order for the assessment year 2017-18 or from the date of issuance of notice u/s 271D of the Act, initiating the proceedings. - AT
Penalty u/s 271D - period of limitation - CIT(A) took the date on which the one year period from the end of the financial year in which the notice was issued as 31/03/2022. - We are unable to understand where from this date has come. Expiry of one year is not relatable to this date either from the date of the assessment order for the assessment year 2017-18 or from the date of issuance of notice u/s 271D of the Act, initiating the proceedings. - AT
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