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...
Deduction of tax at source under section 194J is not conclusive of professional income; tax authorities must independently examine the true nature of receipts before denying presumptive taxation under section 44AD. In the cited matter, the Tribunal set aside the appellate order and restored the case for fresh examination and de novo assessment because the receipts had been treated solely on the basis of the payer's TDS deduction, without an independent enquiry, and the assessee was to be given a reasonable opportunity of hearing.
Deduction of tax at source under section 194J is not conclusive of professional income; tax authorities must independently examine the true nature of receipts before denying presumptive taxation under section 44AD. In the cited matter, the Tribunal set aside the appellate order and restored the case for fresh examination and de novo assessment because the receipts had been treated solely on the basis of the payer's TDS deduction, without an independent enquiry, and the assessee was to be given a reasonable opportunity of hearing.
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