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...
SC allowed appeal against rejection of compounding application for offense under s.276CC for delayed tax return filing. Court held offense under s.276CC is committed day after due date under s.139(1), not on actual filing date. For AY 2013-14, offense occurred on 01.11.2013, before show cause notice dated 27.10.2014 for AY 2011-12 offense. This qualified as "first offense" under 2014 Compounding Guidelines. Court noted evolution toward more flexible compounding regime, with s.276CC now Category A offense allowing up to three compounding occasions. Orders of HC and CCIT rejected, appellant directed to file fresh compounding application within two weeks.
SC allowed appeal against rejection of compounding application for offense under s.276CC for delayed tax return filing. Court held offense under s.276CC is committed day after due date under s.139(1), not on actual filing date. For AY 2013-14, offense occurred on 01.11.2013, before show cause notice dated 27.10.2014 for AY 2011-12 offense. This qualified as "first offense" under 2014 Compounding Guidelines. Court noted evolution toward more flexible compounding regime, with s.276CC now Category A offense allowing up to three compounding occasions. Orders of HC and CCIT rejected, appellant directed to file fresh compounding application within two weeks.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
