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...
Levy of Penalty - Perusal of Rule 26 makes it abundantly clear that unless and until there is sufficient evidence about the mens area/ intent on the part of the appellant which prove that he knew or had reason to believe that excisable goods with which he is involved, he is transporting, removing, depositing, keeping, concealing, selling or purchasing, or in any other manner dealing with such excisable goods, are liable for confiscation, he cannot be penalised under Rule 26. - AT
Levy of Penalty - Perusal of Rule 26 makes it abundantly clear that unless and until there is sufficient evidence about the mens area/ intent on the part of the appellant which prove that he knew or had reason to believe that excisable goods with which he is involved, he is transporting, removing, depositing, keeping, concealing, selling or purchasing, or in any other manner dealing with such excisable goods, are liable for confiscation, he cannot be penalised under Rule 26. - AT
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