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...
Profits arising on sale of land - ‘business income’ OR 'capital gains' - after purchase of land assessee got if converted to NA land - the assessee also got a lay out plan approved from competent authority initially for plotting of land and subsequently to build the residential blocks with small business centre in the intervening period. The facts and circumstances of such sequential events give rise to an infallible impression that the driving force for purchase of land was to exploit it commercially. - AT
Profits arising on sale of land - ‘business income’ OR 'capital gains' - after purchase of land assessee got if converted to NA land - the assessee also got a lay out plan approved from competent authority initially for plotting of land and subsequently to build the residential blocks with small business centre in the intervening period. The facts and circumstances of such sequential events give rise to an infallible impression that the driving force for purchase of land was to exploit it commercially. - AT
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