Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
Partial denial of exemption for benefit to specified persons was confined to the income said to have been diverted; the broader exemption under sections 11 and 12 was not forfeited in full, and the 15 per cent amount treated as deemed application under section 11 was deleted. A payment to a related concern was not hit by the specified concern rule because the trustee's voting power was below the 20 per cent threshold, and a procedural error in Form 10B did not defeat the exemption claim. Capital expenditure was also allowed as application of income on an accrual basis, with supporting invoices, disclosure in the balance sheet, and replies to notices sufficient on the facts.
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