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...
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
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