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...
Levy of penalty - carry forward of excess credit - it was a bona fide mistake of carrying forward excess credit - There is no other allegation or evidence brought on record by the revenue that intentionally and purposefully the Appellant had shown wrong opening balance thereby continued to enjoy excess credit for a period of time till it is pointed out by the audit. Therefore, imposition of penalty equal to the amount of credit availed cannot be sustained. - AT
Levy of penalty - carry forward of excess credit - it was a bona fide mistake of carrying forward excess credit - There is no other allegation or evidence brought on record by the revenue that intentionally and purposefully the Appellant had shown wrong opening balance thereby continued to enjoy excess credit for a period of time till it is pointed out by the audit. Therefore, imposition of penalty equal to the amount of credit availed cannot be sustained. - AT
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