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Section 270A: Demystifying the impact of new penalty regime under Transfer pricing

June 11, 2019[2019] 106 taxmann.com 92 (Article)
Over the years, transfer pricing adjustments have become a common phenomenon for multinational companies engaged in voluminous cross border transaction(s) with related parties. Hitherto, the trend has been that tax authorities have initiated penalty proceedings under section 271(1)(c) of the Income-tax Act, 1961 (the Act) in almost every case where a transfer pricing adjustment has been made. Penalty has even been levied in a number of cases pending at various stages in the appellate hierarchy.
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