Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
Transfer pricing re-characterisation of redeemable preference share subscription and redemption as loans was rejected because earlier decisions in the assessee's own case had already held that, absent material showing sham or concealment of the real character, the TPO could not disregard the apparent transaction or impute notional interest. The interest disallowance on advances to sister concerns also failed because the Tribunal found sufficient own funds on the balance sheets, giving rise to a presumption that the advances came from those funds; that factual finding was not shown to be perverse. Both appeals were dismissed.
Transfer pricing re-characterisation of redeemable preference share subscription and redemption as loans was rejected because earlier decisions in the assessee's own case had already held that, absent material showing sham or concealment of the real character, the TPO could not disregard the apparent transaction or impute notional interest. The interest disallowance on advances to sister concerns also failed because the Tribunal found sufficient own funds on the balance sheets, giving rise to a presumption that the advances came from those funds; that factual finding was not shown to be perverse. Both appeals were dismissed.
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