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 section 271(1)(c) was set aside for fresh adjudication where it was levied solely on the basis of the assessment order, without an independent examination in the penalty proceedings and without proper consideration of the assessee's material; the matter was restored to the Assessing Officer to provide due opportunity and follow natural justice. On penalty under section 271AAA, the Tribunal held that the provision applies only to a "specified previous year" as defined in the Explanation, and A.Y. 2011-12 did not fall within that description, so the penalty was deleted.
Penalty under section 271(1)(c) was set aside for fresh adjudication where it was levied solely on the basis of the assessment order, without an independent examination in the penalty proceedings and without proper consideration of the assessee's material; the matter was restored to the Assessing Officer to provide due opportunity and follow natural justice. On penalty under section 271AAA, the Tribunal held that the provision applies only to a "specified previous year" as defined in the Explanation, and A.Y. 2011-12 did not fall within that description, so the penalty was deleted.
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