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 271AAB - Addition u/s 69B - income shown suo-motto - additional income brought to tax by the Assessing Officer - none of the conditions for levy of penalty at the lower rate of 10%, under clause (a) of Section 271AAB (1), are satisfied. Accordingly, it is held that in respect of such additional income, penalty is leviable at 30% under clause (a) of Section 271AAB(1). - AT
Penalty u/s 271AAB - Addition u/s 69B - income shown suo-motto - additional income brought to tax by the Assessing Officer - none of the conditions for levy of penalty at the lower rate of 10%, under clause (a) of Section 271AAB (1), are satisfied. Accordingly, it is held that in respect of such additional income, penalty is leviable at 30% under clause (a) of Section 271AAB(1). - AT
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