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 levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
Penalty levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
