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...
Disallowance of project expenses - Addition on the ground as no project-wise accounting was available and no work-in-progress was reported - As the assessee is engaged in the business of consultancy services definitely there can be some overlap of the expenses between two years. However that does not give any rise to the AO to disallow the expenditure @10% and treat it as work in progress. - AT
Disallowance of project expenses - Addition on the ground as no project-wise accounting was available and no work-in-progress was reported - As the assessee is engaged in the business of consultancy services definitely there can be some overlap of the expenses between two years. However that does not give any rise to the AO to disallow the expenditure @10% and treat it as work in progress. - AT
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