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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Failure to file a return despite taxable income can constitute under-reporting under section 270A where no original return is furnished and assessed income exceeds the maximum amount not chargeable to tax. The note explains that section 270A is triggered by objective statutory conditions rather than concealment or intent to evade tax. Income disclosed in response to a reassessment notice and accepted without further addition does not cure the initial filing default. Availability of income details through tax deduction at source also does not remove the return-filing obligation. As no exclusion under section 270A(6) was established, penalty under section 270A(7) was sustained.
Failure to file a return despite taxable income can constitute under-reporting under section 270A where no original return is furnished and assessed income exceeds the maximum amount not chargeable to tax. The note explains that section 270A is triggered by objective statutory conditions rather than concealment or intent to evade tax. Income disclosed in response to a reassessment notice and accepted without further addition does not cure the initial filing default. Availability of income details through tax deduction at source also does not remove the return-filing obligation. As no exclusion under section 270A(6) was established, penalty under section 270A(7) was sustained.
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