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...
For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
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