Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
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Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
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