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...
Estimation of income - alleged commission income on accommodation entry - though Section 145(3) gives discretion to the AO to make an assessment in the manner provided in Section 144, yet this discretion cannot be exercised arbitrarily - there should be any material for the basis adopted by the AO or the Tribunal and the material which is irrelevant or which amounts to mere guesswork or conjecture is no material - addition deleted
Estimation of income - alleged commission income on accommodation entry - though Section 145(3) gives discretion to the AO to make an assessment in the manner provided in Section 144, yet this discretion cannot be exercised arbitrarily - there should be any material for the basis adopted by the AO or the Tribunal and the material which is irrelevant or which amounts to mere guesswork or conjecture is no material - addition deleted
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