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...
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Validity of order of Income Tax Settlement Commission [ITSC] - deemed dividend under Section 2(22)(e) - The Revenue need not have any apprehension over the income, which was initially disclosed at the time of filing the application under Section 245C of the Act because the said income, which was offered at the first instance was not accepted by the Revenue and a report under Rule 9 of the said Rules was filed and based on that, the Revenue suggested four additions and thereafter, the case was proceeded and the matter was settled. - HC
Validity of order of Income Tax Settlement Commission [ITSC] - deemed dividend under Section 2(22)(e) - The Revenue need not have any apprehension over the income, which was initially disclosed at the time of filing the application under Section 245C of the Act because the said income, which was offered at the first instance was not accepted by the Revenue and a report under Rule 9 of the said Rules was filed and based on that, the Revenue suggested four additions and thereafter, the case was proceeded and the matter was settled. - HC
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