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 40A(2) - expenditure is excessive or unreasonable having regard to the FMV of the goods, services or facilities - the assessee and Nimbus in negotiations with BCCI agreed neither to refund for the cancelled match nor to charge for the additional match - difference in fee did not prevent the parties from agreeing to fresh contract as to how to adjust the revenue proceeds - no addition
Addition u/s 40A(2) - expenditure is excessive or unreasonable having regard to the FMV of the goods, services or facilities - the assessee and Nimbus in negotiations with BCCI agreed neither to refund for the cancelled match nor to charge for the additional match - difference in fee did not prevent the parties from agreeing to fresh contract as to how to adjust the revenue proceeds - no addition
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