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...
Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
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