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 10(4)(ii) exempts interest on NRE deposits where an individual is either a person resident outside India under FEMA or is permitted by the RBI to maintain the NRE account. A change in residential status is therefore not conclusive of exemption eligibility. Continued authority under the applicable RBI/FEMA framework to maintain NRE deposits requires factual verification. Eligibility must be examined on this limited basis, with an opportunity of hearing, without reopening unrelated issues.
Section 10(4)(ii) exempts interest on NRE deposits where an individual is either a person resident outside India under FEMA or is permitted by the RBI to maintain the NRE account. A change in residential status is therefore not conclusive of exemption eligibility. Continued authority under the applicable RBI/FEMA framework to maintain NRE deposits requires factual verification. Eligibility must be examined on this limited basis, with an opportunity of hearing, without reopening unrelated issues.
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