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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Penalty proceedings u/s 271(1)(b) - non-compliance of statutory notices - it was difficult to comply to the various notices on short dates - compliances had been made through replies filed through dak or registered post though belatedly - All these facts and circumstances under any prudence do constitute reasonable cause u/s 273B - No penalty - AT
Penalty proceedings u/s 271(1)(b) - non-compliance of statutory notices - it was difficult to comply to the various notices on short dates - compliances had been made through replies filed through dak or registered post though belatedly - All these facts and circumstances under any prudence do constitute reasonable cause u/s 273B - No penalty - AT
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