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...
Deemed dividend addition u/s 2(22)(e) - assessee had mortgaged his properties for availing credit limits by the company and dried up his resources for getting financial assistance from the banks. Therefore, he had no option except to take the loan from the assessee company or to get released the properties mortgaged to the Bank - deleted the addition made towards deemed dividend - AT
Deemed dividend addition u/s 2(22)(e) - assessee had mortgaged his properties for availing credit limits by the company and dried up his resources for getting financial assistance from the banks. Therefore, he had no option except to take the loan from the assessee company or to get released the properties mortgaged to the Bank - deleted the addition made towards deemed dividend - AT
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