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...
Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
