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...
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
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