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...
Assessment u/s 153A - benefit of exemption u/s 11 - Bogus purchases - even if the benefits of section 11 is denied than too there can be no income of the appellant trust on which tax can be collected from it in view of the provisions of section 10(23C)(vi) of the Act considering the approval granted to the appellant trust. - after giving effect to exemption under provisions of section 10(23C)(vi) there cannot be any income of the appellant trust which can be charged to tax as the total income of the Appellant society is exempted - AT
Assessment u/s 153A - benefit of exemption u/s 11 - Bogus purchases - even if the benefits of section 11 is denied than too there can be no income of the appellant trust on which tax can be collected from it in view of the provisions of section 10(23C)(vi) of the Act considering the approval granted to the appellant trust. - after giving effect to exemption under provisions of section 10(23C)(vi) there cannot be any income of the appellant trust which can be charged to tax as the total income of the Appellant society is exempted - AT
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