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...
Disallowance of commission expenses - Non-service of letters to the buyers or non-compliance of the letters by the buyers does not show that the payment of commission was not genuine when the relative sale was considered genuine and accepted by the department. Further, non Smt. furnishing of the name of the buyers by agent in compliance to the notice does not necessarily mean that the agent is not aware of the buyers - Claim of expenses cannot be denied - AT
Disallowance of commission expenses - Non-service of letters to the buyers or non-compliance of the letters by the buyers does not show that the payment of commission was not genuine when the relative sale was considered genuine and accepted by the department. Further, non Smt. furnishing of the name of the buyers by agent in compliance to the notice does not necessarily mean that the agent is not aware of the buyers - Claim of expenses cannot be denied - AT
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