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 u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
Penalty u/s 271(1)(b) - Non-compliance with a notice issued u/s 142(1) - The Tribunal noted that in a previous round of proceedings, a penalty under section 271(1)(b) of the Act had been deleted by the Tribunal, indicating a precedent in favor of the appellant. Considering the circumstances, including the quashing of the assessment order by the High Court in the second round of proceedings, the Tribunal found that the penalty imposed in connection with those proceedings was untenable.
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