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...
Penalty u/s. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
Penalty u/s. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
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