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...
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
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