2 results for “transfer pricing”+ Section 271Aclear
Sorted by relevance
In the result, the appeal of the assessee is partly allowed for statistical purposes
Bench: Shri Waseem Ahmed & Shri Soundararajan K
Section 270A, 271A, 271AA and 271BA of the Income Tax Act. The penalty proceedings are premature at this stage; therefore, these are dismissed accordingly as infructuous. 5. The issue raised by the assessee in Grounds Nos. 2 and 4 of the appeal is that the ld. AO/ Ld. DRP erred in treating M/s SanDisk India as a Dependent Agency Permanent