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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Pandemic-related disruption, a plausible bona fide belief about return-filing obligations, and subsequent participation in assessment proceedings are identified as reasonable cause for non-compliance with statutory notices by an educational trust. The note states that mere non-compliance, without independent material showing deliberate or wilful disregard, does not justify penalty. It further describes penalty provisions as quasi-criminal and inapplicable to technical or venial defaults where surrounding circumstances establish reasonable cause. On these grounds, the penalty for non-compliance with statutory notices was described as unsustainable and deleted.
Pandemic-related disruption, a plausible bona fide belief about return-filing obligations, and subsequent participation in assessment proceedings are identified as reasonable cause for non-compliance with statutory notices by an educational trust. The note states that mere non-compliance, without independent material showing deliberate or wilful disregard, does not justify penalty. It further describes penalty provisions as quasi-criminal and inapplicable to technical or venial defaults where surrounding circumstances establish reasonable cause. On these grounds, the penalty for non-compliance with statutory notices was described as unsustainable and deleted.
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