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...
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
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