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...
Levy of penalty u/s 271B - violation to get accounts audited u/s 44AB - The word ‘relevant’ qualifying the words ‘assessment or other order’ in section 275(1)(a) has to be read in a broad, rather than in a narrow, sense, in keeping with the purpose and need for the said exclusion. In the present case, the quantum of turnover is fundamental to the levy of penalty - order within limitation
Levy of penalty u/s 271B - violation to get accounts audited u/s 44AB - The word ‘relevant’ qualifying the words ‘assessment or other order’ in section 275(1)(a) has to be read in a broad, rather than in a narrow, sense, in keeping with the purpose and need for the said exclusion. In the present case, the quantum of turnover is fundamental to the levy of penalty - order within limitation
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