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 u/s. 271B for failure to get accounts audited u/s 44AB - The ITAT held that once a penalty has been levied under Section 271A for non-maintenance of books of accounts, no penalty under Section 271B can be levied. - Citing precedents and relevant case law, the Tribunal emphasized that Section 271B is not applicable when no accounts have been maintained, and recourse to Section 271A should be taken instead.
Levy of Penalty u/s. 271B for failure to get accounts audited u/s 44AB - The ITAT held that once a penalty has been levied under Section 271A for non-maintenance of books of accounts, no penalty under Section 271B can be levied. - Citing precedents and relevant case law, the Tribunal emphasized that Section 271B is not applicable when no accounts have been maintained, and recourse to Section 271A should be taken instead.
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