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) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
Penalty u/s 271(1)(c) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
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