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...
Ad hoc confirmation of one-fifth of an alleged unexplained investment in a flat was found arbitrary where the source of payments was supported by bank transfers, housing finance, accumulated savings from government service, family agricultural income, and the spouse's income; that addition was deleted. The separate addition for the difference between stamp duty value and purchase price was also deleted because the order gave no cogent reason for refusing a valuation reference, relied on the wrong charging provision for the relevant assessment year, and ignored evidence showing demolition action for unauthorised construction, which supported the declared price as the flat's fair market value.
Ad hoc confirmation of one-fifth of an alleged unexplained investment in a flat was found arbitrary where the source of payments was supported by bank transfers, housing finance, accumulated savings from government service, family agricultural income, and the spouse's income; that addition was deleted. The separate addition for the difference between stamp duty value and purchase price was also deleted because the order gave no cogent reason for refusing a valuation reference, relied on the wrong charging provision for the relevant assessment year, and ignored evidence showing demolition action for unauthorised construction, which supported the declared price as the flat's fair market value.
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