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...
Penalty under Section 271(1)(c) was held unsustainable where the underlying quantum addition for alleged bogus purchases represented only an estimated profit element and not a definite, proved concealment. The ITAT deleted the penalty for Assessment Year 2010-2011 on the ground that estimated additions alone do not justify penalty. For Assessment Year 2011-2012, the appellate order sustaining penalty was set aside because the assessee's submissions had not been considered; the matter was remanded for fresh adjudication after giving reasonable opportunity and addressing the material placed on record.
Penalty under Section 271(1)(c) was held unsustainable where the underlying quantum addition for alleged bogus purchases represented only an estimated profit element and not a definite, proved concealment. The ITAT deleted the penalty for Assessment Year 2010-2011 on the ground that estimated additions alone do not justify penalty. For Assessment Year 2011-2012, the appellate order sustaining penalty was set aside because the assessee's submissions had not been considered; the matter was remanded for fresh adjudication after giving reasonable opportunity and addressing the material placed on record.
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