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...
Addition u/s 68B - acceptance of additions by the assessee contrary to legal position - it cannot be treated as a sale transaction at all being without consideration, factum of merely accepting the addition made by AO u/s 69B, would not change the legal position.
Addition u/s 68B - acceptance of additions by the assessee contrary to legal position - it cannot be treated as a sale transaction at all being without consideration, factum of merely accepting the addition made by AO u/s 69B, would not change the legal position.
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