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 271AAB - treating an amount included in the Return of Income as undisclosed income susceptible to penalty - search conducted u/s 132, assessment carried out u/s 153A, additions made u/s 50C - assessee contended that without search, income from Long Term Capital Gains (LTCG) and cash transactions would not have been disclosed - Held: No reference to any statement recorded u/s 132(4) showing admission of undisclosed income, a prerequisite for invoking Section 271AAB(1A). Income from LTCG and cash transactions not alleged to be false by Revenue. LTCG otherwise taxable, transactions routed through banking channels, advance tax paid, hence cannot be treated as undisclosed income. Coordinate Bench decision in assessee's wife's case affirmed the view. Imposition of 30% penalty on alleged undisclosed income u/s 271AAB(1A)(a) not justified.
Penalty u/s 271AAB - treating an amount included in the Return of Income as undisclosed income susceptible to penalty - search conducted u/s 132, assessment carried out u/s 153A, additions made u/s 50C - assessee contended that without search, income from Long Term Capital Gains (LTCG) and cash transactions would not have been disclosed - Held: No reference to any statement recorded u/s 132(4) showing admission of undisclosed income, a prerequisite for invoking Section 271AAB(1A). Income from LTCG and cash transactions not alleged to be false by Revenue. LTCG otherwise taxable, transactions routed through banking channels, advance tax paid, hence cannot be treated as undisclosed income. Coordinate Bench decision in assessee's wife's case affirmed the view. Imposition of 30% penalty on alleged undisclosed income u/s 271AAB(1A)(a) not justified.
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