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 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
Penalty under section 271C was held unsustainable where the order was passed beyond the six-month limit prescribed by section 275(1)(c), as fiscal limitation provisions must be strictly applied and penalty cannot be imposed after expiry of that period. The tribunal also noted that the alleged default arose from a disallowance treated as interest-related expenditure, yet the reference for penalty was made after an inordinate 18-month delay. That delay was found to defeat the object of section 275(1)(c), and the penalty order, as well as the appellate affirmation, was set aside and the penalty deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
