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...
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
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