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...
The assessee made an undisclosed income declaration under Income Declaration Scheme-2016 for the assessment years 2010-11, 2011-12, and 2014-15, clubbing the income for 2012-13. The Principal Commissioner specified the amounts to be paid as tax, surcharge, and penalty in three installments. The assessee defaulted on the third installment payment due by 30.09.2017. However, a notification dated 13.02.2019 extended the payment date to 31.01.2020, along with 1% monthly interest, retrospectively effective from 01.06.2016. The assessee paid the balance tax with interest. The ITAT held that the assessee validly deposited the tax, surcharge, interest, and penalty under IDS-2016 and the 13.12.2019 notification, rectifying the default retrospectively. The CIT(A) failed to appreciate this retrospective rectification. Therefore, the issue was determined in favor of the assessee against the revenue.
The assessee made an undisclosed income declaration under Income Declaration Scheme-2016 for the assessment years 2010-11, 2011-12, and 2014-15, clubbing the income for 2012-13. The Principal Commissioner specified the amounts to be paid as tax, surcharge, and penalty in three installments. The assessee defaulted on the third installment payment due by 30.09.2017. However, a notification dated 13.02.2019 extended the payment date to 31.01.2020, along with 1% monthly interest, retrospectively effective from 01.06.2016. The assessee paid the balance tax with interest. The ITAT held that the assessee validly deposited the tax, surcharge, interest, and penalty under IDS-2016 and the 13.12.2019 notification, rectifying the default retrospectively. The CIT(A) failed to appreciate this retrospective rectification. Therefore, the issue was determined in favor of the assessee against the revenue.
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