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...
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Diallowance of expenses after estimation of profit u/s 144 - ITAT deleted the additions - It is not required for the AO to apply net profit at a particular rate while finalising the assessment u/s144 of the Act. Method for estimating the income in the previous year of the assessee on the basis of net profit at a particular rate cannot be applied for all subsequent years - Order of ITAT set aside.
Diallowance of expenses after estimation of profit u/s 144 - ITAT deleted the additions - It is not required for the AO to apply net profit at a particular rate while finalising the assessment u/s144 of the Act. Method for estimating the income in the previous year of the assessee on the basis of net profit at a particular rate cannot be applied for all subsequent years - Order of ITAT set aside.
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