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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Write-off of dues arising from commodity trading transactions was deductible where the assessee had written the amount off in the profit and loss account during the relevant year and the transactions were undertaken in the ordinary course of business. Contract notes, delivery reports and broker ledger confirmation supported the claim, and the pendency of recovery proceedings did not make it premature. The deduction was allowed as bad debt and, alternatively, as a business loss; the disallowance was deleted.
Write-off of dues arising from commodity trading transactions was deductible where the assessee had written the amount off in the profit and loss account during the relevant year and the transactions were undertaken in the ordinary course of business. Contract notes, delivery reports and broker ledger confirmation supported the claim, and the pendency of recovery proceedings did not make it premature. The deduction was allowed as bad debt and, alternatively, as a business loss; the disallowance was deleted.
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