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...
Bogus purchases - department had neither disputed the assessee's sales nor shown any discrepancy between the purchases shown and the sales declared - the Tribunal was correct in coming to the conclusion that the purchases cannot be rejected without disturbing the sales in case of a trader - correctly restricted the additions @ of G.P. rate on purchases at the same rate of other genuine purchases
Bogus purchases - department had neither disputed the assessee's sales nor shown any discrepancy between the purchases shown and the sales declared - the Tribunal was correct in coming to the conclusion that the purchases cannot be rejected without disturbing the sales in case of a trader - correctly restricted the additions @ of G.P. rate on purchases at the same rate of other genuine purchases
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