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...
MAT computation - Valuation of assets on amalgamation - determining book profit - Since, the capital reserve is out of purview of Section 115JB, and the “Revaluation Reserve” only is considered for upward adjustment of the profit as per the Act, the AO tried to being the capital reserve to the fold of Clause (j) [which rightly deals with revaluation reserve]. Such an action of the AO cannot be sustained. - AT
MAT computation - Valuation of assets on amalgamation - determining book profit - Since, the capital reserve is out of purview of Section 115JB, and the “Revaluation Reserve” only is considered for upward adjustment of the profit as per the Act, the AO tried to being the capital reserve to the fold of Clause (j) [which rightly deals with revaluation reserve]. Such an action of the AO cannot be sustained. - AT
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