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...
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
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