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...
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
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