Tax Assessments and Tax Litigation Involving an Indian Subsidiary
First written in FY2016-Q3. 15 of 28 entries say "Advanced", first in FY2017-Q2. Latest entry: FY2025-H1.
1 other company's latest entry also says "Mitigated".
- FY2025-H1MitigatedAnnual report
「For the fiscal years ended March 2012, March 2013, March 2014 and March 2016, the tax tribunal issued decisions rescinding the reassessment orders based on notices issued by the Indian tax authorities and remanding the matters to those authorities for review. For the fiscal years ended March 2012 and March 2013, the limitation period expired without a reinvestigation, and meetings with the tax officers confirmed that they did not intend to appeal. For the fiscal years ended March 2014 and March 2016, the tax authorities conducted reassessments and accepted the company's claims as valid. Accordingly, these 4 fiscal years have been excluded from contingent liabilities.」
The 4 prior-year cases were excluded from contingent liabilities because the limitation period had expired, the absence of any intention to appeal had been confirmed, or the company's claims had been accepted as valid following reassessment. The unresolved cases therefore decreased from the previous 8 fiscal years to 4. - FY2024AdvancedAnnual report
「Decision dismissing objection — 5 July 2024 Appeal filed with the tax tribunal — 30 August 2024 Tax stated in reassessment notice — INR 87 million (¥150 million)」
Regarding the reassessment for the fiscal year ended March 2020, the matter proceeded to an appeal before the tax tribunal after dismissal of the objection. The tax stated in the reassessment notice was recorded as INR 87 million (¥150 million). - FY2024-Q2RestatedAnnual report
「The Indian consolidated subsidiary ASB INTERNATIONAL PVT. LTD. received reassessment notices from the Indian tax authorities concerning transfer pricing between related companies and other matters for 8 fiscal years ended in March, as shown in the table below. The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year. For each fiscal year in which the objection was dismissed, the company will file an appeal with the tax tribunal and proceed with an application for the mutual agreement procedure, continuing to assert the validity of the positions of the company and its consolidated subsidiary.」
The policy concerning reassessment notices, objections, appeals to the tax tribunal after dismissal, and applications for the mutual agreement procedure for 8 fiscal years involving transfer pricing between related companies and other matters continued to be reported. - FY2023AdvancedAnnual report
「(8) Fiscal year ended March 2020 Receipt of reassessment notice — 29 September 2023 Tax stated in reassessment notice — INR 51 million (¥93 million) Objection filed — 23 October 2023」
The fiscal years covered by reassessment notices concerning transfer pricing between related companies and other matters expanded from 7 to 8, with a new reassessment notice and objection recorded for the fiscal year ended March 2020. - FY2023-Q3RestatedAnnual report
「The Indian consolidated subsidiary ASB INTERNATIONAL PVT. LTD. received reassessment notices from the Indian tax authorities concerning transfer pricing between related companies and other matters for 7 fiscal years ended in March, as shown in the table below. The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year. For each fiscal year in which the objection was dismissed, the company will file an appeal with the tax tribunal and proceed with an application for the mutual agreement procedure, continuing to assert the validity of the positions of the company and its consolidated subsidiary.」
The policy concerning reassessment notices, objections, appeals to the tax tribunal after dismissal, and applications for the mutual agreement procedure for 7 fiscal years involving transfer pricing between related companies and other matters remains in place. - FY2023-Q2RestatedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 7 fiscal years ended in March, as shown in the table below. The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year.」
The policy concerning reassessment notices, objections, appeals to the tax tribunal after dismissal, and applications for the mutual agreement procedure for 7 fiscal years continued to be reported. - FY2022AdvancedAnnual report
「Decision dismissing objection — 29 August 2022 Appeal filed with the tax tribunal — 27 October 2022 Tax stated in reassessment notice — INR 97 million (¥174 million)」
Regarding the reassessment for the fiscal year ended March 2018, the matter proceeded to an appeal before the tax tribunal in October 2022, following dismissal of the objection in August 2022. - FY2022-Q3RestatedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 9 fiscal years ended in March, as shown in the table below. The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year.」
The reassessment notices, objections and policy of filing appeals with the tax tribunal after dismissal of the objections for 9 fiscal years continued to be reported. The matters for the fiscal years ended March 2010 and March 2011 were considered resolved through rescission of the reassessment orders. - FY2022-Q2AdvancedAnnual report
「Decision dismissing objection — 17 February 2022 Appeal filed with the tax tribunal — 12 April 2022 Tax stated in reassessment notice — INR 80 million (¥131 million)」
It was recorded that, following dismissal of the objection regarding the reassessment for the fiscal year ended March 2017, the matter proceeded to an appeal before the tax tribunal. The tax stated in the reassessment notice at the time of filing the appeal was INR 80 million (¥131 million). - FY2022-Q1RestatedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 9 fiscal years ended in March, as shown in the table below. The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year.」
The reassessment notices, objections and policy of filing appeals with the tax tribunal after dismissal of the objections for 9 fiscal years continued to be reported. The matters for the fiscal years ended March 2010 and March 2011 were considered resolved through rescission of the reassessment orders. - FY2021AdvancedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 9 fiscal years ended in March, as shown in the table below.」
The fiscal years covered by reassessment notices concerning transfer pricing between related companies and other matters expanded from 8 to 9, with a new reassessment notice and objection recorded for the fiscal year ended March 2018. - FY2021-Q3RestatedAnnual report
「The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year. However, for each fiscal year in which the relevant authority dismissed the objection, the company plans to file, or promptly file, an appeal with the tax tribunal against the final reassessment order in order to further assert the validity of its position.」
The reassessments and objections concerning transfer pricing between related companies and other matters for 8 fiscal years, together with the policy of filing appeals with the tax tribunal after dismissal of the objections, continued to be reported. The matters for the fiscal years ended March 2010 and March 2011 were considered resolved through rescission of the reassessment orders. - FY2021-Q2AdvancedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 8 fiscal years ended in March, as shown in the table below.」
The cases covered expanded from 7 fiscal years previously to 8, with a new reassessment notice received on 20 April 2021 for the fiscal year ended March 2017. For the fiscal year ended March 2016, a decision dismissing the objection was recorded on 4 March 2021, and proceedings toward tax litigation also remain pending. - FY2020-Q2AdvancedAnnual report
「The Indian tax authorities issued reassessment notices concerning transfer pricing between related companies and other matters for 7 fiscal years ended in March, as shown in the table below. For the fiscal years ended March 2010 and March 2011, the company subsequently received notices from the relevant authority rescinding the reassessment orders, thereby resolving the matters.」
While the cases covered were organized as 7 fiscal years, the matter for the fiscal year ended March 2010 was also resolved upon receipt of a notice rescinding the reassessment order. Proceedings for the fiscal years ended March 2014, March 2015, March 2016 and other periods remain pending. - FY2020-Q1AdvancedAnnual report
「For the fiscal year ended March 2015, the company filed an appeal with the tax tribunal on 30 December 2019. For the fiscal year ended March 2016, it received a reassessment notice on 25 December 2019 and filed an objection on 23 January 2020.」
The reassessment for the fiscal year ended March 2015 proceeded to an appeal before the tax tribunal, while a new reassessment notice and objection arose for the fiscal year ended March 2016. As prior-year cases were rescinded and resolved, proceedings concerning transfer pricing between related companies and other matters continued, covering additional fiscal years. - FY2019AdvancedAnnual report
「For the fiscal years ended March 2010, March 2011, March 2012 and March 2013, the tax tribunal issued decisions rescinding the reassessment orders based on notices issued by the Indian tax authorities and remanding the matters to those authorities for review.」
A tax tribunal decision dated 13 September 2019 rescinding and remanding the matters was recorded for the fiscal years ended March 2012 and March 2013. The matter for the fiscal year ended March 2011 was resolved upon receipt of a notice rescinding the reassessment order, while proceedings for the fiscal years ended March 2014, March 2015 and other periods remain pending. - FY2019-Q3RestatedAnnual report
「The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year. However, for each fiscal year in which the relevant authority dismissed the objection, the company plans to file, or promptly file, an appeal with the tax tribunal against the final reassessment order in order to further assert the validity of its position.」
The reassessments, objections and policy of filing appeals with the tax tribunal concerning transfer pricing between related companies and other matters for 6 fiscal years were reproduced. It was also confirmed that the matter for the fiscal year ended March 2011 had been resolved upon receipt of a notice rescinding the reassessment order. - FY2019-Q2RestatedAnnual report
「The company considered the findings of the Indian tax authorities to lack a valid basis and the reassessment orders unacceptable, and therefore filed an objection with the Indian tax authorities' Dispute Resolution Panel for each fiscal year. However, for each fiscal year in which the relevant authority dismissed the objection, the company plans to file, or promptly file, an appeal with the tax tribunal against the final reassessment order in order to further assert the validity of its position.」
The status of reassessments, objections and tax litigation concerning transfer pricing between related companies and other matters for the 6 fiscal years reported through the previous quarter was reproduced. Resolution through rescission of the reassessment order for the fiscal year ended March 2011 was also confirmed, and no new material procedural developments were reported. - FY2019-Q1AdvancedAnnual report
「For the fiscal year ended March 2011, the company subsequently received a notice from the relevant authority rescinding the reassessment order, thereby resolving the matter. For the fiscal year ended March 2014, the company filed an appeal with the tax tribunal on 2 November 2018. For the fiscal year ended March 2015, it received a reassessment notice on 12 December 2018 and filed an objection on 11 January 2019.」
The reassessment for the fiscal year ended March 2011 was resolved upon receipt of a notice rescinding the reassessment order. Meanwhile, the fiscal year ended March 2014 proceeded to an appeal before the tax tribunal, while a new reassessment notice and objection were recorded for the fiscal year ended March 2015, indicating that the proceedings had progressed and expanded. - FY2018AdvancedAnnual report
「Receipt of reassessment notice — 30 November 2017 Tax stated in reassessment notice — INR 40 million (¥63 million) Objection filed — 29 December 2017 Decision dismissing objection — 27 August 2018」
A reassessment notice for the fiscal year ended March 2014 concerning transfer pricing between related companies and other matters was newly recorded. Following the filing of an objection, the objection was dismissed, and proceedings moved toward tax litigation. - FY2018-Q3AdvancedAnnual report
「For the fiscal years ended March 2010 and March 2011, the tax tribunal issued decisions rescinding the reassessment orders based on notices issued by the Indian tax authorities and remanding the matters to those authorities for review.」
A tax tribunal decision dated 29 May 2018 was recorded for the fiscal year ended March 2010, resulting, together with the fiscal year ended March 2011, in rescission and remand of the reassessment notices. Proceedings for other periods concerning transfer pricing between related companies and other matters remain pending. - FY2018-Q1AdvancedAnnual report
「Appeal filed with the tax tribunal — 21 December 2017 Objection filed — 29 December 2017」
The company filed an appeal with the tax tribunal on 21 December 2017 regarding the reassessment for the fiscal year ended March 2013, and filed an objection on 29 December of the same year regarding the reassessment for the fiscal year ended March 2014. - FY2017AdvancedAnnual report
「However, for each fiscal year in which the relevant authority rejected the objection, the company plans to file, or promptly file, an appeal with the tax tribunal against the final reassessment order in order to further assert the validity of its position.」
While the company achieved a substantive victory in the remaining cases concerning tax exemptions and minimum alternate tax, the periods covered by the proceedings concerning transfer pricing between related companies and other matters expanded to 5 fiscal years, and the process of filing appeals with the tax tribunal following dismissal of the objections continued and became more concrete. - FY2017-Q3Substantive victories in some cases; other cases remain pendingAnnual report
「In addition, on 3 June 2017, the company received a notice from the tax tribunal regarding the remaining amount of INR 42,988 thousand (¥65.343 million in the previous consolidated fiscal year and ¥75.230 million in the current third-quarter consolidated period), in which the company's claims were substantially accepted, resulting in a substantive victory.」
The company also achieved a substantive victory regarding the remaining reassessment amounts related to tax exemptions and minimum alternate tax. Meanwhile, reassessment proceedings for multiple fiscal years concerning transfer pricing between related companies and other matters, as well as appeals to the tax tribunal, remain pending. - FY2017-Q2AdvancedAnnual report
「Filed with the tax tribunal — 14 March 2017」
The company proceeded to file an appeal with the tax tribunal regarding the reassessment for the fiscal year ended March 2012. As previously reported, the tax tribunal issued a decision rescinding and remanding the matter for the fiscal year ended March 2011, while the objection for the fiscal year ended March 2013 remains pending. - FY2017-Q1Progress on some matters; separate matter ongoingAnnual report
「For the fiscal year ended March 2011, the tax tribunal issued a ruling annulling the decision of the Indian tax authorities and remanding the matter to those authorities.」
The tax tribunal's ruling annulling and remanding the reassessment for the fiscal year ended March 2011 was described, while procedures relating to other matters, including the reassessment notice and objection for the fiscal year ended March 2013, remained ongoing. - FY2016Partial reduction; separate matter ongoingAnnual report
「On 29 June 2012, the tax tribunal largely accepted the company's claims, resulting in a substantially favorable ruling. Consequently, the amount covered by the tax reassessment notices received by the company was reduced to INR 42,988 thousand, equivalent to ¥78.669 million for the previous consolidated fiscal year and ¥65.343 million for the current consolidated fiscal year. In addition, the company received tax reassessment notices from the Indian tax authorities concerning intercompany transfer pricing and other matters, covering the 4 fiscal years ending in March shown in the table below.」
The reassessments concerning the previous tax exemptions and minimum alternate tax were substantially resolved in the company's favor by the tax tribunal, reducing the amount involved, while reassessment notices concerning intercompany transfer pricing and other matters for multiple fiscal years, together with objections and litigation, remained ongoing. - FY2016-Q3MaterialisedAnnual report
「ASB INTERNATIONAL PVT. LTD., an Indian consolidated subsidiary, had received tax reassessment notices from the Indian tax authorities totaling INR 90,100 thousand, relating to the application of tax exemptions for export-oriented units (EOUs) and the calculation of minimum alternate tax. The amounts were ¥164.883 million for the previous consolidated fiscal year and ¥137.853 million for the nine months ended the current third quarter. The company considered the notices unjustified and lacking a valid basis, filed objections, and brought part of the matter before the tax tribunal.」
Following receipt of the tax reassessment notices, the company filed objections and brought part of the matter before the tax tribunal. Separate reassessment notices concerning intercompany transfer pricing and other matters were also described.