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...
HC held that the Transfer Pricing Officer (TPO) improperly rejected the assessee's transfer pricing study for intra-group services. The ITAT's decision to remand the matter was upheld, requiring the TPO to re-examine the transfer pricing analysis and verify whether conditions under Section 92C(3) are satisfied before making any adjustment. The fundamental premise of the TPO that no services were received was rejected, necessitating a comprehensive reassessment of the intra-group service transaction's arm's length pricing.
HC held that the Transfer Pricing Officer (TPO) improperly rejected the assessee's transfer pricing study for intra-group services. The ITAT's decision to remand the matter was upheld, requiring the TPO to re-examine the transfer pricing analysis and verify whether conditions under Section 92C(3) are satisfied before making any adjustment. The fundamental premise of the TPO that no services were received was rejected, necessitating a comprehensive reassessment of the intra-group service transaction's arm's length pricing.
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