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...
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
Omission of section 92BA(1) without a saving clause rendered the provision nonexistent, therefore any assessment officer reference to the transfer pricing officer to determine the arm's length price of specified domestic transactions lacked jurisdiction and the TPO's consequential order was invalid; the appellate authority has deleted the additions and the revenue appeal was dismissed, applying the principle that where a statutory provision is omitted from the statute book the AO cannot invoke that provision to re open or adjust domestic transfer pricing.
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TaxTMI 
TaxTMI 
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