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...
Default in furnishing TCS statements - statement submitted u/s 200(3) are to be processed u/s 200A and then AO can levy fine u/s 234E - once a procedure has been provided by the legislature, then it does not give discretion to the AO to levy fine without processing the statements - Merely mentioning S. 234E would not become an order u/s 234E in isolation - appeal maintainable
Default in furnishing TCS statements - statement submitted u/s 200(3) are to be processed u/s 200A and then AO can levy fine u/s 234E - once a procedure has been provided by the legislature, then it does not give discretion to the AO to levy fine without processing the statements - Merely mentioning S. 234E would not become an order u/s 234E in isolation - appeal maintainable
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