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 u/s 271C - Short deduction of tax at source (TDS) in respect of Brand fee paid - The argument of the assessee that short deduction does not cause loss to the revenue is not a reasonable explanation and it shows the willful default of the assessee for short deduction - AT
Penalty u/s 271C - Short deduction of tax at source (TDS) in respect of Brand fee paid - The argument of the assessee that short deduction does not cause loss to the revenue is not a reasonable explanation and it shows the willful default of the assessee for short deduction - AT
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