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...
Penalty u/s 271D and penalty u/s. 271E - Default u/s 269SS and u/s 269T - Loan/deposits taken/paid by the assessee in cash is more than Rs.20,000/- - after evaluating the provisions of law, aggregate of loan is to be seen personwise and not aggregate loan taken from all the persons in the whole year. Therefore, under these present facts and circumstances of the case, the penalty is not attracted in the present case- AT
Penalty u/s 271D and penalty u/s. 271E - Default u/s 269SS and u/s 269T - Loan/deposits taken/paid by the assessee in cash is more than Rs.20,000/- - after evaluating the provisions of law, aggregate of loan is to be seen personwise and not aggregate loan taken from all the persons in the whole year. Therefore, under these present facts and circumstances of the case, the penalty is not attracted in the present case- AT
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