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 interest u/s. 36(1)(iii) - The authorities below have neither given any cogent reasons for rejecting the contention of the assessee based on the audited books of account nor brought on record any evidence to rebut the contention of the assessee. There is no evidence on record to arrive at the conclusion that the advances in question were made during the year relevant to the assessment year under consideration - Additions to be deleted - AT
Disallowance of interest u/s. 36(1)(iii) - The authorities below have neither given any cogent reasons for rejecting the contention of the assessee based on the audited books of account nor brought on record any evidence to rebut the contention of the assessee. There is no evidence on record to arrive at the conclusion that the advances in question were made during the year relevant to the assessment year under consideration - Additions to be deleted - AT
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