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...
On a conjoint reading of the conveyance deed and consent terms, the assessee was found to have relinquished all rights, title, interest and possession in the entire larger land, so the consideration was treated as a global settlement for extinguishment of the whole bundle of rights. The Tribunal held that the assessee's development and possessory rights were themselves a capital asset, and their extinguishment amounted to a transfer. As the indexed cost claimed related to those intangible rights, not to ownership of the physical land, restriction of cost by reference only to the portion conveyed was unsustainable. The deletion of the addition was upheld.
On a conjoint reading of the conveyance deed and consent terms, the assessee was found to have relinquished all rights, title, interest and possession in the entire larger land, so the consideration was treated as a global settlement for extinguishment of the whole bundle of rights. The Tribunal held that the assessee's development and possessory rights were themselves a capital asset, and their extinguishment amounted to a transfer. As the indexed cost claimed related to those intangible rights, not to ownership of the physical land, restriction of cost by reference only to the portion conveyed was unsustainable. The deletion of the addition was upheld.
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