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...
Levy of penalties both u/s 114 and Section 114AA on both of the CB and the exporter together - The appellant was also not seen to be a part of a conspiracy to defraud the exchequer, however he has made a mistake by a conscious disregard of the illegality and in not distancing himself from the act and reporting the matter that he knew was wrong and this blameworthy conduct warrants a penalty. However, the penalty imposed in this case is shocking and requires to be modified. - AT
Levy of penalties both u/s 114 and Section 114AA on both of the CB and the exporter together - The appellant was also not seen to be a part of a conspiracy to defraud the exchequer, however he has made a mistake by a conscious disregard of the illegality and in not distancing himself from the act and reporting the matter that he knew was wrong and this blameworthy conduct warrants a penalty. However, the penalty imposed in this case is shocking and requires to be modified. - AT
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