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...
Levy of penalty - Smuggling of Gold - seizure - Commissioner (Appels) set aside the penalty - The Tribunal found insufficient evidence to establish the Respondents ownership. Statements of key witnesses lacked consistency, and procedural irregularities in the examination of witnesses weakened the case. Therefore, the court upheld the impugned order, dismissing the Revenue's appeal and maintaining the decision to set aside the penalty on the Respondents.
Levy of penalty - Smuggling of Gold - seizure - Commissioner (Appels) set aside the penalty - The Tribunal found insufficient evidence to establish the Respondents ownership. Statements of key witnesses lacked consistency, and procedural irregularities in the examination of witnesses weakened the case. Therefore, the court upheld the impugned order, dismissing the Revenue's appeal and maintaining the decision to set aside the penalty on the Respondents.
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