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...
Ad-hoc disallowance of various expenses on the ground that said expenses incurred in cash and not further, supported by necessary bills and vouchers - once the Assessing Officer having accepted fact that cash payments for purchases does not exceed prescribed limit provided under the Act, then erred in making 20% ad-hoc disallowance of expenses. CIT(A), after considering relevant facts has rightly deleted additions made by the AO - AT
Ad-hoc disallowance of various expenses on the ground that said expenses incurred in cash and not further, supported by necessary bills and vouchers - once the Assessing Officer having accepted fact that cash payments for purchases does not exceed prescribed limit provided under the Act, then erred in making 20% ad-hoc disallowance of expenses. CIT(A), after considering relevant facts has rightly deleted additions made by the AO - AT
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