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...
The High Court quashed the penalty order u/s 271(1)(c) passed by the National Faceless Assessment Centre against the petitioner without providing an opportunity of hearing. The matter was remanded back to pass a fresh penalty order after granting an opportunity of hearing to the petitioner in accordance with law, as the Tribunal had already granted substantial relief to the petitioner on merits in the appeals filed by both parties.
The High Court quashed the penalty order u/s 271(1)(c) passed by the National Faceless Assessment Centre against the petitioner without providing an opportunity of hearing. The matter was remanded back to pass a fresh penalty order after granting an opportunity of hearing to the petitioner in accordance with law, as the Tribunal had already granted substantial relief to the petitioner on merits in the appeals filed by both parties.
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