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...
Bogus STCL - Disallowance of Loss arising from the trading in shares - accommodation entry of STCL - the fact remains that the findings of the lower authorities are not based on evidence but on generalizations and probabilities. The AO could not place anything on record, maybe through a process of his own enquiry, to decisively prove that assessee has obtained bogus STCL through his connivance with entry operators / exit providers. - The claim of the assessee appears to have been rejected more on the basis of presumption rather than evidence. - Additions deleted - AT
Bogus STCL - Disallowance of Loss arising from the trading in shares - accommodation entry of STCL - the fact remains that the findings of the lower authorities are not based on evidence but on generalizations and probabilities. The AO could not place anything on record, maybe through a process of his own enquiry, to decisively prove that assessee has obtained bogus STCL through his connivance with entry operators / exit providers. - The claim of the assessee appears to have been rejected more on the basis of presumption rather than evidence. - Additions deleted - AT
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