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...
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
