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...
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
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