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...
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Penalty u/s. 271A - confusion between the ‘books of account’ as per section 44AA and the ‘accounts’ as per section 145(3) - no finding either by the AO or by the CIT(A) that books or documents being not maintained by the assessee - not maintaining ‘proper accounts' will not attract penalty u/s. 271A
Penalty u/s. 271A - confusion between the ‘books of account’ as per section 44AA and the ‘accounts’ as per section 145(3) - no finding either by the AO or by the CIT(A) that books or documents being not maintained by the assessee - not maintaining ‘proper accounts' will not attract penalty u/s. 271A
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