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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Penalty u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
Penalty u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
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