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 271(1)(c) - Since the assessee had furnished full particulars about the expenditure incurred including non–deduction of TDS in the tax audit report itself, it cannot be accused of furnishing inaccurate particulars of income - failure to disallow the amount u/s 40(a)(ia) was due to a bona fide mistake is acceptable - penalty deleted
Penalty u/s 271(1)(c) - Since the assessee had furnished full particulars about the expenditure incurred including non–deduction of TDS in the tax audit report itself, it cannot be accused of furnishing inaccurate particulars of income - failure to disallow the amount u/s 40(a)(ia) was due to a bona fide mistake is acceptable - penalty deleted
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