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...
Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
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