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...
Disallowance of finance costs - proof of business expenses - Share in Joint Venture (JV) - Since assessee is not carrying on any business activity on its own, the question of allowing the deduction u/s. 36(1)(iii) of the Act does not arise as there is no business activity and the investment itself cannot be considered as ‘for the purpose of business’ as there is no business activity at all.
Disallowance of finance costs - proof of business expenses - Share in Joint Venture (JV) - Since assessee is not carrying on any business activity on its own, the question of allowing the deduction u/s. 36(1)(iii) of the Act does not arise as there is no business activity and the investment itself cannot be considered as ‘for the purpose of business’ as there is no business activity at all.
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