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...
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
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