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) - deduction u/s 80IA(4) denied as industrial undertaking was not approved by the CBDT - the assessee has made a claim anticipating sanction of scheme by the CBDT and it has disclosed this fact during the course of assessment proceedings - no deliberate effort was made for withholding such information or furnishing inaccurate particulars - no penalty
Penalty u/s 271(1)(c) - deduction u/s 80IA(4) denied as industrial undertaking was not approved by the CBDT - the assessee has made a claim anticipating sanction of scheme by the CBDT and it has disclosed this fact during the course of assessment proceedings - no deliberate effort was made for withholding such information or furnishing inaccurate particulars - no penalty
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