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...
Addition u/s 68 - share capital and share premium - no enquiries were conducted by the ld AO u/s 133(6) and/or 131 from the share subscribers - the assessee by producing necessary documents viz. detailed chart of inflow and outflow of funds, IT records, audited Balance Sheets, bank statement copy etc of self and all other parties involved - sufficiently established the identity and creditworthiness of the share subscribers and the genuineness of the share transaction - no addition
Addition u/s 68 - share capital and share premium - no enquiries were conducted by the ld AO u/s 133(6) and/or 131 from the share subscribers - the assessee by producing necessary documents viz. detailed chart of inflow and outflow of funds, IT records, audited Balance Sheets, bank statement copy etc of self and all other parties involved - sufficiently established the identity and creditworthiness of the share subscribers and the genuineness of the share transaction - no addition
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