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 proceedings u/s 271FA - late filing of the SFT statement Online by the appellant - appellant opted for the Vivad Se Vishwas Scheme and paid the due amount - Form No.4 was not submitted electronically - The Tribunal accepted the manual submission of Form No. 4 under the Vivad Se Vishwas Scheme, considering technical difficulties faced by the appellant. - The Tribunal allowed the appeal of the assessee, providing relief from the penalty imposed under section 271FA of the Income Tax Act.
Penalty proceedings u/s 271FA - late filing of the SFT statement Online by the appellant - appellant opted for the Vivad Se Vishwas Scheme and paid the due amount - Form No.4 was not submitted electronically - The Tribunal accepted the manual submission of Form No. 4 under the Vivad Se Vishwas Scheme, considering technical difficulties faced by the appellant. - The Tribunal allowed the appeal of the assessee, providing relief from the penalty imposed under section 271FA of the Income Tax Act.
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