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 u/s.271(1)(C) - paints were his “personal effects” - the plea of the assessee that receipts from sale of paintings were not offered to tax on a bona fide belief is acceptable. - as there was neither concealment of particulars of income or furnishing of inaccurate particulars of income, no penalty - AT
Penalty u/s.271(1)(C) - paints were his “personal effects” - the plea of the assessee that receipts from sale of paintings were not offered to tax on a bona fide belief is acceptable. - as there was neither concealment of particulars of income or furnishing of inaccurate particulars of income, no penalty - AT
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