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...
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Levy of penalty on the petitioner being double the amount of tax allegedly evaded by the petitioner - No doubt, in circumstances where the gross profit estimated by the revenue authorities is significantly higher than what is conceded by the assessee, and it is apparent that the estimation itself was done in an unscientific manner, it may be open to an assessee to challenge the same inter alia based on the decisions mentioned. On the facts of the instant case, however, Tribunal order is reasonable accepting the additions made by AO - HC
Levy of penalty on the petitioner being double the amount of tax allegedly evaded by the petitioner - No doubt, in circumstances where the gross profit estimated by the revenue authorities is significantly higher than what is conceded by the assessee, and it is apparent that the estimation itself was done in an unscientific manner, it may be open to an assessee to challenge the same inter alia based on the decisions mentioned. On the facts of the instant case, however, Tribunal order is reasonable accepting the additions made by AO - HC
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