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...
Waiver of interest u/s 234B - interest in defaults in payment of advance tax - The phrase ‘or otherwise’ used in Section 234B(2) would encompass situations of remittances made in any other context, wherein the amounts paid stood to the credit of the petitioner. - there is a delay of one and two years respectively, as the amounts for which credit is sought ought to have been remitted in FY 2010-11, relevant to AY 2011-12. To this extent, the petitioner is liable to interest in terms of Section 234B. - HC
Waiver of interest u/s 234B - interest in defaults in payment of advance tax - The phrase ‘or otherwise’ used in Section 234B(2) would encompass situations of remittances made in any other context, wherein the amounts paid stood to the credit of the petitioner. - there is a delay of one and two years respectively, as the amounts for which credit is sought ought to have been remitted in FY 2010-11, relevant to AY 2011-12. To this extent, the petitioner is liable to interest in terms of Section 234B. - HC
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