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...
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
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