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...
Validity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
Validity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
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