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...
Mis-declared/un-declared imported goods - Evidently, no panchnama was drawn by Revenue for retrieval of data or documents from the CPU/mobile of the appellant - The seizure is bad under the provisions of Section 110 of the Act. It is found that the show cause notice is vague as it does not specify the particular clause of Section 111, under which the goods are liable for confiscation. Further, in the facts and circumstances, the imposition of penalty under Section 112 and 114 AA is bad. - AT
Mis-declared/un-declared imported goods - Evidently, no panchnama was drawn by Revenue for retrieval of data or documents from the CPU/mobile of the appellant - The seizure is bad under the provisions of Section 110 of the Act. It is found that the show cause notice is vague as it does not specify the particular clause of Section 111, under which the goods are liable for confiscation. Further, in the facts and circumstances, the imposition of penalty under Section 112 and 114 AA is bad. - AT
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