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...
Subsidy or incentive - purpose tests for grant of subsidy/incentive - incentives received in the form of Sales Tax and Central Excise benefit - revenue or capital receipt - If on facts it was proved that subsidy was granted under schemes framed by the State and the Central Government, to set up new industry in Kutch District or to encourage investment which would in turn, provide fresh employment opportunity in the district which had suffered due to devastating earthquake then applying purpose test it would in capital nature.
Subsidy or incentive - purpose tests for grant of subsidy/incentive - incentives received in the form of Sales Tax and Central Excise benefit - revenue or capital receipt - If on facts it was proved that subsidy was granted under schemes framed by the State and the Central Government, to set up new industry in Kutch District or to encourage investment which would in turn, provide fresh employment opportunity in the district which had suffered due to devastating earthquake then applying purpose test it would in capital nature.
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