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 56(2)(vii)(b) does not apply to an HUF where documentary evidence shows that immovable property was acquired by its Karta in an individual capacity. The sale agreement, patta and encumbrance certificate supported individual ownership, while an erroneous reference to the HUF PAN in the sale deed did not establish that the HUF funded or owned the property. The addition based on the difference between stamp-duty value and consideration was therefore deleted. Documents considered by the appellate authority were already furnished during reassessment, so their consideration did not constitute admission of additional evidence under Rule 46A.
Section 56(2)(vii)(b) does not apply to an HUF where documentary evidence shows that immovable property was acquired by its Karta in an individual capacity. The sale agreement, patta and encumbrance certificate supported individual ownership, while an erroneous reference to the HUF PAN in the sale deed did not establish that the HUF funded or owned the property. The addition based on the difference between stamp-duty value and consideration was therefore deleted. Documents considered by the appellate authority were already furnished during reassessment, so their consideration did not constitute admission of additional evidence under Rule 46A.
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