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...
Disallowance u/s 14A - CIT(A) deleted the suomotu disallowance made by the assessee and upheld by ITAT - claim that an income not taxable is wrongly offered for tax will not operate as any kind of estoppel against the assessee regardless whether the revised return was filed or not - Revenue is obliged to assess the correct income - suomotu disallowance correctly deleted
Disallowance u/s 14A - CIT(A) deleted the suomotu disallowance made by the assessee and upheld by ITAT - claim that an income not taxable is wrongly offered for tax will not operate as any kind of estoppel against the assessee regardless whether the revised return was filed or not - Revenue is obliged to assess the correct income - suomotu disallowance correctly deleted
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