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...
TP adjustment - goods Exported to the Associated Enterprises (AE) - The Tribunal sided with the assessee, noting the principle of consistency should apply, as similar methodologies were accepted in previous years. They directed the deletion of the transfer pricing adjustment, emphasizing that the profitability of AEs in initial operational stages in new markets can justifiably be lower.
TP adjustment - goods Exported to the Associated Enterprises (AE) - The Tribunal sided with the assessee, noting the principle of consistency should apply, as similar methodologies were accepted in previous years. They directed the deletion of the transfer pricing adjustment, emphasizing that the profitability of AEs in initial operational stages in new markets can justifiably be lower.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
