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...
The substituted definition of "specified sum" in the Explanation to the cash-receipt provision, introduced by the Finance Act, 2023 with effect from 01.04.2023, could not be applied to assessment year 2013-14. The Tribunal held that the Assessing Officer's reliance on that amended definition for cash advances received in a residential project was legally impermissible. As a result, the application of the cash-acceptance provision to the transaction was authority of law, and the consequential penalty for such cash acceptance could not survive; the penalty and appellate orders were quashed.
The substituted definition of "specified sum" in the Explanation to the cash-receipt provision, introduced by the Finance Act, 2023 with effect from 01.04.2023, could not be applied to assessment year 2013-14. The Tribunal held that the Assessing Officer's reliance on that amended definition for cash advances received in a residential project was legally impermissible. As a result, the application of the cash-acceptance provision to the transaction was authority of law, and the consequential penalty for such cash acceptance could not survive; the penalty and appellate orders were quashed.
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