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...
Unclaimed student caution money held by a charitable trust was treated as a refundable security deposit and not as a trading liability or an amount on which deduction had earlier been allowed. As the amount was neither forfeited nor written back and the trust continued to recognise it in its books, there was no remission or cessation of liability; mere lapse of time did not extinguish the debt, so the addition under section 41(1) failed. On interest paid to specified persons, the Tribunal upheld the finding that the rate was excessive, and the surviving disallowance under section 40A(2) was sustained.
Unclaimed student caution money held by a charitable trust was treated as a refundable security deposit and not as a trading liability or an amount on which deduction had earlier been allowed. As the amount was neither forfeited nor written back and the trust continued to recognise it in its books, there was no remission or cessation of liability; mere lapse of time did not extinguish the debt, so the addition under section 41(1) failed. On interest paid to specified persons, the Tribunal upheld the finding that the rate was excessive, and the surviving disallowance under section 40A(2) was sustained.
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