Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum Healthcare, were met, justifying the inclusion of interest on delayed receivables as a separate international transaction. The Tribunal emphasized the need for proper inquiry by the Transfer Pricing Officer (TPO) over time to identify patterns indicating benefits to AEs, and rejected the appellant's argument that the receivables' impact was already considered in the working capital adjustment.
TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum Healthcare, were met, justifying the inclusion of interest on delayed receivables as a separate international transaction. The Tribunal emphasized the need for proper inquiry by the Transfer Pricing Officer (TPO) over time to identify patterns indicating benefits to AEs, and rejected the appellant's argument that the receivables' impact was already considered in the working capital adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
