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...
Government grants earmarked for specified purposes and subject to utilisation restrictions do not constitute the recipient's income; accordingly, an unspent micro-irrigation scheme grant was not taxable. Interest payable on unutilised grant under applicable Government resolutions was treated as an allowable liability. Under the block-of-assets principle, depreciation remains available where business assets form part of a used block, even if individual assets have been retired from active use; simultaneous use of every asset is unnecessary. The related depreciation disallowance was deleted, and the capital-gains issue was treated as academic.
Government grants earmarked for specified purposes and subject to utilisation restrictions do not constitute the recipient's income; accordingly, an unspent micro-irrigation scheme grant was not taxable. Interest payable on unutilised grant under applicable Government resolutions was treated as an allowable liability. Under the block-of-assets principle, depreciation remains available where business assets form part of a used block, even if individual assets have been retired from active use; simultaneous use of every asset is unnecessary. The related depreciation disallowance was deleted, and the capital-gains issue was treated as academic.
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