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...
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
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