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...
Interest differential credited to statutory development funds was treated as diverted at source under the scheme directions, so it was not taxable in the assessee's hands; the Tribunal followed its earlier orders in the assessee's own case and noted that the assessee acted only as a nodal or implementing agency. Promotional and developmental expenditure was also allowed because the assessee had been notified from financial year 2012-13, applicable from assessment year 2013-14, so the basis of disallowance failed. The Revenue's appeal was dismissed and the appellate order was upheld in full.
Interest differential credited to statutory development funds was treated as diverted at source under the scheme directions, so it was not taxable in the assessee's hands; the Tribunal followed its earlier orders in the assessee's own case and noted that the assessee acted only as a nodal or implementing agency. Promotional and developmental expenditure was also allowed because the assessee had been notified from financial year 2012-13, applicable from assessment year 2013-14, so the basis of disallowance failed. The Revenue's appeal was dismissed and the appellate order was upheld in full.
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