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...
The HC dismissed the challenge, holding that the assessee had disclosed acquisition of the foreign asset in the original returns for AY 2012-13 and 2013-14 and in the return filed under s.153A prior to issuance of any penalty notice; books of account corroborated the disclosure. Applying the principle that a return filed under s.153A qualifies as a return for purposes of s.139(1), the tribunal and commissioner correctly concluded there was no failure to disclose and that imposition of the Rs.10 lakh penalty was not warranted on account of a remediable technical formatting defect. No substantial question of law arises.
The HC dismissed the challenge, holding that the assessee had disclosed acquisition of the foreign asset in the original returns for AY 2012-13 and 2013-14 and in the return filed under s.153A prior to issuance of any penalty notice; books of account corroborated the disclosure. Applying the principle that a return filed under s.153A qualifies as a return for purposes of s.139(1), the tribunal and commissioner correctly concluded there was no failure to disclose and that imposition of the Rs.10 lakh penalty was not warranted on account of a remediable technical formatting defect. No substantial question of law arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
