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...
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Disallowance u/s 14A r.w rule 8D(2)(iii) - since there is no tax free income, there could not be any disallowance u/s 14A - AO directed to re-compute the income of the assessee after excluding the suo motto amount disallowed by the assessee. Apart from the above disallowance made by the AO on account of administrative expenses is concerned, this also stands deleted.
Disallowance u/s 14A r.w rule 8D(2)(iii) - since there is no tax free income, there could not be any disallowance u/s 14A - AO directed to re-compute the income of the assessee after excluding the suo motto amount disallowed by the assessee. Apart from the above disallowance made by the AO on account of administrative expenses is concerned, this also stands deleted.
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