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...
Penalty imposed u/s 112(a) - Import confectionary items from Dubai - immunity from prosecution and fine/penalty - Tribunal held that since the appellant was a co-noticee along with the main accused, appellant was also entitled to immunity granted by the Settlement Commission to the main noticee - The High Court held that, the reasoning of the Tribunal extending immunity granted to the other co-noticees to the respondent is not sustainable. - Matter restored back before tribunal for re-judication in view of the earlier decision of the High Court.
Penalty imposed u/s 112(a) - Import confectionary items from Dubai - immunity from prosecution and fine/penalty - Tribunal held that since the appellant was a co-noticee along with the main accused, appellant was also entitled to immunity granted by the Settlement Commission to the main noticee - The High Court held that, the reasoning of the Tribunal extending immunity granted to the other co-noticees to the respondent is not sustainable. - Matter restored back before tribunal for re-judication in view of the earlier decision of the High Court.
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