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In the result, appeal filed by the assessee is allowed
Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh
Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal