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...
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
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