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...
Deduction u/s 36(1)(viia) - provision created for bad and doubtful debts - RBI guidelines prescribes the provision on standard assets from the year ended March 31, 2000 directing the banks to make a general provision of a minimum of 0.25% on standard assets. - Decision rendered by the CIT is unjustifiable for the reason that assessee is bound by the guidelines issued by the Reserve Bank of India.
Deduction u/s 36(1)(viia) - provision created for bad and doubtful debts - RBI guidelines prescribes the provision on standard assets from the year ended March 31, 2000 directing the banks to make a general provision of a minimum of 0.25% on standard assets. - Decision rendered by the CIT is unjustifiable for the reason that assessee is bound by the guidelines issued by the Reserve Bank of India.
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