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...
Penalty for failure to obtain an audit report was deleted because the assessee had consistently treated sale of shops as giving rise to capital gains, and the characterisation of the activity as business or investment was a debatable issue. The Tribunal found that the transactions were identical to those in the preceding year, when penalty had already been cancelled, and there was no distinguishing feature to justify a different view. On these facts, the assessee's bona fide belief that audit was not required constituted reasonable cause under section 273B, so penalty under section 271B could not be sustained.
Penalty for failure to obtain an audit report was deleted because the assessee had consistently treated sale of shops as giving rise to capital gains, and the characterisation of the activity as business or investment was a debatable issue. The Tribunal found that the transactions were identical to those in the preceding year, when penalty had already been cancelled, and there was no distinguishing feature to justify a different view. On these facts, the assessee's bona fide belief that audit was not required constituted reasonable cause under section 273B, so penalty under section 271B could not be sustained.
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