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 of interest - assessee had taken unsecured loans from the family members of the partners in the earlier years and paying interest @ 15% on the same - Fresh borrowing during the year from HDFC bank has been utilized for advancing to the partners and the family members and there is thus a direct nexus - it would have been appropriate to compare the related party transaction with an independent third party transaction carrying the same qualitative unsecured loan parameters.
Disallowance of interest - assessee had taken unsecured loans from the family members of the partners in the earlier years and paying interest @ 15% on the same - Fresh borrowing during the year from HDFC bank has been utilized for advancing to the partners and the family members and there is thus a direct nexus - it would have been appropriate to compare the related party transaction with an independent third party transaction carrying the same qualitative unsecured loan parameters.
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