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...
Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
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