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...
Revision u/s 264 - penalty u/s 270A imposed - waiver of penalty u/s 270AA - The very fact that the indications were made that the matter fall within (a) and (c), necessarily means that even the revisional authority was not sure whether it was a case of misrepresentation or suppression of facts or claim of expense, not substantiated by any evidence. - Order passed by the assessing authority rejecting application u/s 270AA and the order passed by the revisional authority rejecting revision petition, cannot be sustained. - HC
Revision u/s 264 - penalty u/s 270A imposed - waiver of penalty u/s 270AA - The very fact that the indications were made that the matter fall within (a) and (c), necessarily means that even the revisional authority was not sure whether it was a case of misrepresentation or suppression of facts or claim of expense, not substantiated by any evidence. - Order passed by the assessing authority rejecting application u/s 270AA and the order passed by the revisional authority rejecting revision petition, cannot be sustained. - HC
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