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...
Voluntary surrender of income by assessee cannot be considered concealment. AO failed to prove concealment, merely concluded voluntary surrender as concealment. Voluntary surrender does not fall under deemed concealment as per Explanation 5A to section 271(1)(c). AO erred in levying penalty u/s 271(1)(c) by invoking Explanation 5A. CIT(A) sustained penalty without appreciating facts. ITAT set aside CIT(A) order, directed AO to delete penalty u/s 271(1)(c). Assessee's appeal allowed.
Voluntary surrender of income by assessee cannot be considered concealment. AO failed to prove concealment, merely concluded voluntary surrender as concealment. Voluntary surrender does not fall under deemed concealment as per Explanation 5A to section 271(1)(c). AO erred in levying penalty u/s 271(1)(c) by invoking Explanation 5A. CIT(A) sustained penalty without appreciating facts. ITAT set aside CIT(A) order, directed AO to delete penalty u/s 271(1)(c). Assessee's appeal allowed.
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