Tag Archives: Int Tax

No Penalty Lies for Non-Reporting of PE-Unrelated Transactions and CIT(A) Cannot Enhance on New Grounds

By | July 15, 2026

No Penalty Lies for Non-Reporting of PE-Unrelated Transactions and CIT(A) Cannot Enhance on New Grounds Issue Issue I (Section 271AA Penalty): Whether a transfer pricing penalty under Section 271AA for non-reporting of an international transaction is sustainable when the transaction was executed directly by the foreign head office without any effective nexus to its Indian… Read More »