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...
Balance-sheet reclassifications arising from capitalisation of project expenditure and reversal of duplicate entries do not, by themselves, create taxable income. Transfer of Capital Work-in-Progress or pre-operative expenditure to fixed assets is characterised as a balance-sheet movement rather than revenue expenditure where no debit is made to the Profit and Loss Account and no deduction is claimed in computing income. A reduction in an asset account cannot support an addition merely from a numerical difference; taxability requires examination of corresponding ledger entries and a demonstrated charging or deeming basis, taxable benefit, remission, or inadmissible expenditure. The notes state that the Revenue's additions were deleted on these grounds.
Balance-sheet reclassifications arising from capitalisation of project expenditure and reversal of duplicate entries do not, by themselves, create taxable income. Transfer of Capital Work-in-Progress or pre-operative expenditure to fixed assets is characterised as a balance-sheet movement rather than revenue expenditure where no debit is made to the Profit and Loss Account and no deduction is claimed in computing income. A reduction in an asset account cannot support an addition merely from a numerical difference; taxability requires examination of corresponding ledger entries and a demonstrated charging or deeming basis, taxable benefit, remission, or inadmissible expenditure. The notes state that the Revenue's additions were deleted on these grounds.
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