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) - advance written off - business or capital loss - genuineness of loss is not in dispute - in the assessment order there is no mention about furnishing of inaccurate particulars and simply made disallowed - in penalty order AO has not specified which particular furnished by the assessee was incorrect, erroneous or false - no penalty
Penalty u/s 271(1)(c) - advance written off - business or capital loss - genuineness of loss is not in dispute - in the assessment order there is no mention about furnishing of inaccurate particulars and simply made disallowed - in penalty order AO has not specified which particular furnished by the assessee was incorrect, erroneous or false - no penalty
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