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...
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
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