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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
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