Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Reason to believe as an essential ingredient for imposing a penalty under section 112(b) is examined, with emphasis on corroboration failures and circumstantial indicators permitting an inference of prior knowledge rather than innocent carriage; the account's unverifiable intermediary, non traceable contact details and voluntary no objection to seizure supported that inference, sustaining the legal basis for penalty. The article also explains that judicial discretion may moderate penalty quantum on humanitarian and equitable grounds where confiscation and prosecution remain in place, resulting in reduced monetary penalties.
Reason to believe as an essential ingredient for imposing a penalty under section 112(b) is examined, with emphasis on corroboration failures and circumstantial indicators permitting an inference of prior knowledge rather than innocent carriage; the account's unverifiable intermediary, non traceable contact details and voluntary no objection to seizure supported that inference, sustaining the legal basis for penalty. The article also explains that judicial discretion may moderate penalty quantum on humanitarian and equitable grounds where confiscation and prosecution remain in place, resulting in reduced monetary penalties.
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