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...
Penalty under s. 270A(1) r/w s. 270A(9)(c) for alleged false expense claims was examined where the underlying addition comprised an ad hoc disallowance sustained at 20% on an estimated basis. Since the income adjustment was purely estimative and did not meet the statutory parameters of "under-reported income" warranting penal consequences, and the AO had not recorded the requisite satisfaction to justify levy under s. 270A, the penalty was held arbitrary and void ab initio. Penalty was quashed and the appeal was allowed. - ITAT
Penalty under s. 270A(1) r/w s. 270A(9)(c) for alleged false expense claims was examined where the underlying addition comprised an ad hoc disallowance sustained at 20% on an estimated basis. Since the income adjustment was purely estimative and did not meet the statutory parameters of "under-reported income" warranting penal consequences, and the AO had not recorded the requisite satisfaction to justify levy under s. 270A, the penalty was held arbitrary and void ab initio. Penalty was quashed and the appeal was allowed. - ITAT
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