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 on sale of Transferable Development Rights (TDR) - AO noted that despite receiving income the assessee has not offered the same to tax - assessee had to surrender 27% of the vacant plot and in lieu thereof subsequently it got TDR - CIT(A) deleted the additions - CIT(A)’s order is nonspeaking and laconic cannot be sustained.
Addition on sale of Transferable Development Rights (TDR) - AO noted that despite receiving income the assessee has not offered the same to tax - assessee had to surrender 27% of the vacant plot and in lieu thereof subsequently it got TDR - CIT(A) deleted the additions - CIT(A)’s order is nonspeaking and laconic cannot be sustained.
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