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...
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
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