Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
