Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Penalty under section 271B was deleted because the assessee's accounts were audited within the prescribed time and only the uploading of the audit report was delayed due to technical glitches in the e-filing portal. The Tribunal treated this as substantial compliance with the audit requirement, held the lapse to be procedural rather than substantive, and found that the report was available before scrutiny assessment was completed without any prejudice to the Revenue. On that basis, the default was regarded as technical and venial, attracting protection under section 273B and not warranting penalty.
Penalty under section 271B was deleted because the assessee's accounts were audited within the prescribed time and only the uploading of the audit report was delayed due to technical glitches in the e-filing portal. The Tribunal treated this as substantial compliance with the audit requirement, held the lapse to be procedural rather than substantive, and found that the report was available before scrutiny assessment was completed without any prejudice to the Revenue. On that basis, the default was regarded as technical and venial, attracting protection under section 273B and not warranting penalty.
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