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 proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
Penalty proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
