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 failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.
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