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...
Section 270A requires a specific statutory charge before enhanced penalty for misreporting can be imposed. Under-reporting is distinct from under-reporting resulting from misreporting, and misreporting must fall within one of the exhaustively listed instances in section 270A(9)(a) to (g). Where the charge shifts during proceedings and the applicable statutory limb is not identified, the defect is non-curable and vitiates the penalty proceedings. Enhanced penalty for alleged misreporting was therefore deleted because the precise charge and statutory basis were not specified.
Section 270A requires a specific statutory charge before enhanced penalty for misreporting can be imposed. Under-reporting is distinct from under-reporting resulting from misreporting, and misreporting must fall within one of the exhaustively listed instances in section 270A(9)(a) to (g). Where the charge shifts during proceedings and the applicable statutory limb is not identified, the defect is non-curable and vitiates the penalty proceedings. Enhanced penalty for alleged misreporting was therefore deleted because the precise charge and statutory basis were not specified.
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