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...
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
Weighted deduction for research and development was confined to expenditure approved by the prescribed authority, but the unapproved revenue outlay retained its character as business expenditure and was allowed under general deduction principles. The Tribunal also applied the presumption that investments were made from interest-free funds where own funds exceeded investments, so the interest component of the exempt-income disallowance was deleted and the balance was to be recomputed only against investments yielding exempt income. Rent paid to related parties for a farmhouse was only partly supported by business use, so the disallowance was restricted to 50%.
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