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) - while declining deduction u/s 80IA no defect was pointed out by the A.O. with regard to assessee’s eligibility save and except there was delay in filing return of income - raising a bona fide legal claim, even if it is ultimately found to be legally not acceptable, could not amount to concealing particulars of income or furnishing of inaccurate particulars of income - no penalty
Penalty u/s 271(1)(c) - while declining deduction u/s 80IA no defect was pointed out by the A.O. with regard to assessee’s eligibility save and except there was delay in filing return of income - raising a bona fide legal claim, even if it is ultimately found to be legally not acceptable, could not amount to concealing particulars of income or furnishing of inaccurate particulars of income - no penalty
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