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) - Defective notice u/s 274 - in the assessment order, AO has made it clear that penalty proceedings are initiated separately for furnishing inaccurate particulars of income, therefore the AO has already indicated that why the penalty proceedings are initiated. - Though the notice u/s 274 has been found as valid, the penalty levied on the estimation of income deleted - AT
Penalty u/s 271(1)(c) - Defective notice u/s 274 - in the assessment order, AO has made it clear that penalty proceedings are initiated separately for furnishing inaccurate particulars of income, therefore the AO has already indicated that why the penalty proceedings are initiated. - Though the notice u/s 274 has been found as valid, the penalty levied on the estimation of income deleted - AT
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