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 ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
The ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
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