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 under-reporting under section 270A was inapplicable where lease-rental disallowance for non-deduction of tax at source arose from a bona fide, debatable interpretation of GNOIDA's status as a Government body. The taxpayer had disclosed the material facts, and neither the Assessing Officer nor the Commissioner (Appeals) found the explanation to lack bona fides. Confirmation of the underlying disallowance alone did not establish under-reporting for penalty purposes. The penalty was therefore deleted, applying the principle that an unsuccessful claim does not by itself justify penalty where the explanation is bona fide and fully disclosed.
Penalty for under-reporting under section 270A was inapplicable where lease-rental disallowance for non-deduction of tax at source arose from a bona fide, debatable interpretation of GNOIDA's status as a Government body. The taxpayer had disclosed the material facts, and neither the Assessing Officer nor the Commissioner (Appeals) found the explanation to lack bona fides. Confirmation of the underlying disallowance alone did not establish under-reporting for penalty purposes. The penalty was therefore deleted, applying the principle that an unsuccessful claim does not by itself justify penalty where the explanation is bona fide and fully disclosed.
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