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...
Addition on account of cash found short u/s 68 and also holding that the same to be taxed u/s 115BBE - Cash short, at the most represents expenses / outgoings out of cash available with the assessee not accounted for in the books of the assessee - How therefore can they be treated or deemed to be income of the assessee u/s 69/69B/69C of the Act when the said sections deem investments/money, the source of which the assessee offers no explanation about, as income of the assessee? - Additions deleted - AT
Addition on account of cash found short u/s 68 and also holding that the same to be taxed u/s 115BBE - Cash short, at the most represents expenses / outgoings out of cash available with the assessee not accounted for in the books of the assessee - How therefore can they be treated or deemed to be income of the assessee u/s 69/69B/69C of the Act when the said sections deem investments/money, the source of which the assessee offers no explanation about, as income of the assessee? - Additions deleted - AT
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