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...
Receipt of advance - Additions u/s 56(2)(vi) - A receipt cannot be taxed merely on conjecture or surmises. - The AO needs to bring on record evidence which proves that the particular receipt is taxable under the provisions of the Act - merely because the person, who paid the amount does not initiate any action for recovery of money should not be not a reason for making addition towards amount received as assessee’s income - AT
Receipt of advance - Additions u/s 56(2)(vi) - A receipt cannot be taxed merely on conjecture or surmises. - The AO needs to bring on record evidence which proves that the particular receipt is taxable under the provisions of the Act - merely because the person, who paid the amount does not initiate any action for recovery of money should not be not a reason for making addition towards amount received as assessee’s income - AT
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