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 271(1)(c) - Failure to file the Return of Income (ITR) - The appellate tribunal addressed two appeals filed by the assessee against penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2011-12 and 2015-16. In the case of the former, the penalty was upheld, despite the appellant's argument of being a non-resident with limited knowledge of Indian tax laws. However, for the latter assessment year, the tribunal ruled in favor of the assessee, citing a similar precedent and considering the appellant's circumstances. The decision emphasized the importance of timely compliance with tax obligations and the relevance of the appellant's awareness of their tax liabilities.
Penalty u/s 271(1)(c) - Failure to file the Return of Income (ITR) - The appellate tribunal addressed two appeals filed by the assessee against penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2011-12 and 2015-16. In the case of the former, the penalty was upheld, despite the appellant's argument of being a non-resident with limited knowledge of Indian tax laws. However, for the latter assessment year, the tribunal ruled in favor of the assessee, citing a similar precedent and considering the appellant's circumstances. The decision emphasized the importance of timely compliance with tax obligations and the relevance of the appellant's awareness of their tax liabilities.
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