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...
Levy of penalty u/s 271B - default u/s 44AB - failure to get accounts get audited - Contradictory stand of the appellant when he contended that due to seizure of books by the sales tax authorities, audit of accounts under Section 44AB of the Act got delayed. Additionally, Tribunal held that appellant did not file the income tax return voluntarily but it was in response to a notice under Section 148 of the Act. - Penalty confirmed - HC
Levy of penalty u/s 271B - default u/s 44AB - failure to get accounts get audited - Contradictory stand of the appellant when he contended that due to seizure of books by the sales tax authorities, audit of accounts under Section 44AB of the Act got delayed. Additionally, Tribunal held that appellant did not file the income tax return voluntarily but it was in response to a notice under Section 148 of the Act. - Penalty confirmed - HC
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