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...
Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
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