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...
The Appellate Tribunal considered the issue of penalty u/s 271(1)(c) of the Act. It was questioned whether a precise charge was brought against the assessee and if the assessing officer had recorded proper satisfaction. The assessee offered additional income during a search related to inflated marketing expenses. The Tribunal found that the assessing officer did not specify the charge in the penalty proceedings notice, rendering the initiation of penalty proceedings invalid. The vague notice issued was deemed void, leading to the penalty order being quashed in favor of the assessee.
The Appellate Tribunal considered the issue of penalty u/s 271(1)(c) of the Act. It was questioned whether a precise charge was brought against the assessee and if the assessing officer had recorded proper satisfaction. The assessee offered additional income during a search related to inflated marketing expenses. The Tribunal found that the assessing officer did not specify the charge in the penalty proceedings notice, rendering the initiation of penalty proceedings invalid. The vague notice issued was deemed void, leading to the penalty order being quashed in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.