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) - disallowance of transport expenses - payment made in cash - Just because the payments were made in cash cannot be a basis to doubt the genuineness of the expenditure. Since the disallowance are made on adhoc basis by applying the rate of 15%, holding the assessee liable to pay penalty for furnishing inaccurate particulars of income cannot be held to be justified. - AT
Penalty u/s 271(1)(c) - disallowance of transport expenses - payment made in cash - Just because the payments were made in cash cannot be a basis to doubt the genuineness of the expenditure. Since the disallowance are made on adhoc basis by applying the rate of 15%, holding the assessee liable to pay penalty for furnishing inaccurate particulars of income cannot be held to be justified. - AT
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