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...
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
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