Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
HC dismissed the writ petition challenging a penalty order under Section 271D of the Income Tax Act. The court held that the limitation period for passing the penalty order was extended till 31.03.2022 through Notification No.113/2021, rendering the order dated 19.08.2021 within valid jurisdiction. The petitioner's arguments regarding premature order and awaiting appellate commissioner's decision were rejected. The court granted liberty to the petitioner to file an appeal before the Appellate Commissioner under Section 246A within 30 days of receiving the order's copy, effectively upholding the penalty order's validity.
HC dismissed the writ petition challenging a penalty order under Section 271D of the Income Tax Act. The court held that the limitation period for passing the penalty order was extended till 31.03.2022 through Notification No.113/2021, rendering the order dated 19.08.2021 within valid jurisdiction. The petitioner's arguments regarding premature order and awaiting appellate commissioner's decision were rejected. The court granted liberty to the petitioner to file an appeal before the Appellate Commissioner under Section 246A within 30 days of receiving the order's copy, effectively upholding the penalty order's validity.
Note: It is a system-generated summary and is for quick reference only.