Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Non-compliance with notices under section 142(1) did not justify penalty under section 272A(1)(d) where the assessee later furnished detailed replies with supporting material, the Assessing Officer verified and accepted that material, and the assessment was completed under section 143(3). The Tribunal treated the earlier default as merged in the subsequent compliance and as deemed condoned by the regular assessment, so the penalty was held not leviable and was deleted in the lead matter and connected appeals.
Non-compliance with notices under section 142(1) did not justify penalty under section 272A(1)(d) where the assessee later furnished detailed replies with supporting material, the Assessing Officer verified and accepted that material, and the assessment was completed under section 143(3). The Tribunal treated the earlier default as merged in the subsequent compliance and as deemed condoned by the regular assessment, so the penalty was held not leviable and was deleted in the lead matter and connected appeals.
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