Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Absence of recorded satisfaction in the assessment order for initiating penalty proceedings rendered penalty under section 271E unsustainable, where the assessment under section 143(3) accepted the returned income and contained no finding of violation of section 269T. Applying CIT v. Jai Laxmi Rice Mills, the Tribunal held that penalty proceedings cannot survive without such satisfaction in the assessment order and directed deletion of the penalty.
Absence of recorded satisfaction in the assessment order for initiating penalty proceedings rendered penalty under section 271E unsustainable, where the assessment under section 143(3) accepted the returned income and contained no finding of violation of section 269T. Applying CIT v. Jai Laxmi Rice Mills, the Tribunal held that penalty proceedings cannot survive without such satisfaction in the assessment order and directed deletion of the penalty.
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