Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
Assessee failed to establish eligibility for immunity under section 270AA(3) because no application in Form 68-online or manual-was produced or acknowledged; alleged technical glitch was unsubstantiated. The reasoning applies the requirement that an immunity application must be filed and evidenced, and that absence of Form 68 or acknowledgment supports a finding of under reporting. Consequent to these factual and evidentiary findings, penalty liability under section 270A was sustained and the appeal was dismissed.
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