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...
Levy of penalty - Smuggling - parts of wild animals - Prohibited goods or not - the Revenue failed to conclusively prove that the goods in question were prohibited items as alleged. The reliance on the visual examination by an inspector from the Forest Department, who was not an expert and whose opinion was uncertain and inconclusive, was deemed insufficient. The Tribunal noted the lack of a definitive conclusion or written opinion regarding the nature of the consignments. - AT
Levy of penalty - Smuggling - parts of wild animals - Prohibited goods or not - the Revenue failed to conclusively prove that the goods in question were prohibited items as alleged. The reliance on the visual examination by an inspector from the Forest Department, who was not an expert and whose opinion was uncertain and inconclusive, was deemed insufficient. The Tribunal noted the lack of a definitive conclusion or written opinion regarding the nature of the consignments. - AT
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