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...
Suppression of tax - alleged unaccounted sales - scope of the word 'an estimate' - one need not dwell into all details furnished by the Intelligence Officer in Annexure-A order. It is not the case of dealer that the details, for any purpose, incorporated in the penalty order are incorrect, unrelated etc. The apportionment of profit, percentage, etc are again in line with the method adopted by the dealer. The Intelligence Officer has found out the suppression of sales turnover in a particular sale transaction through artificial and unacceptable apportionment of sale price between taxable item and exempt item. - The only ground raised by referring to estimation of suppressed turnover is equally untenable and accordingly rejected. - HC
Suppression of tax - alleged unaccounted sales - scope of the word 'an estimate' - one need not dwell into all details furnished by the Intelligence Officer in Annexure-A order. It is not the case of dealer that the details, for any purpose, incorporated in the penalty order are incorrect, unrelated etc. The apportionment of profit, percentage, etc are again in line with the method adopted by the dealer. The Intelligence Officer has found out the suppression of sales turnover in a particular sale transaction through artificial and unacceptable apportionment of sale price between taxable item and exempt item. - The only ground raised by referring to estimation of suppressed turnover is equally untenable and accordingly rejected. - HC
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