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...
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
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