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) - wrong claim of TDS which not belong to the assessee but appeared in the form No.26AS - there was no addition made to the income of the assessee of any kind whatsoever qua this TDS claim - the provisions of section 271(1)(c) do not apply to the present case as there was neither concealment of income nor furnishing of inaccurate particulars
Penalty u/s 271(1)(c) - wrong claim of TDS which not belong to the assessee but appeared in the form No.26AS - there was no addition made to the income of the assessee of any kind whatsoever qua this TDS claim - the provisions of section 271(1)(c) do not apply to the present case as there was neither concealment of income nor furnishing of inaccurate particulars
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