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. 271B - absence of auditing u/s. 44AB - The very fact that the assessee got its accounts audited under the Cooperative Societies Act prima facie shows that it entertained a bona fide belief that the amount of grant-in-aid received from Government of Maharashtra was not includible for the purposes of computing turnover u/s. 44AB. - Since the penalty section is covered u/s. 273B, we hold that the penalty was not required to be levied and confirmed. - AT
Penalty u/s. 271B - absence of auditing u/s. 44AB - The very fact that the assessee got its accounts audited under the Cooperative Societies Act prima facie shows that it entertained a bona fide belief that the amount of grant-in-aid received from Government of Maharashtra was not includible for the purposes of computing turnover u/s. 44AB. - Since the penalty section is covered u/s. 273B, we hold that the penalty was not required to be levied and confirmed. - AT
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