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...
Penalty u/s 271D & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
Penalty u/s 271D & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
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