Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
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