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...
Disallowance of deduction claimed u/s 10AA after claiming deduction / exemption u/s 10A - SEZ unit - As on the commencement of assessment year 2006-07, which is the effective date of operation of section 10AA, the unit has just claimed deduction under section 10A only for five assessment years and therefore, the assessee has submitted that the assessee company is entitled for deduction under section 10AA. - the assessee is entitled for deduction u/s 10AA(1)(ii) of the 1961 Act for the impugned assessment year, subject to fulfilment of other conditions for grant of deduction u/s 10AA of the 1961 Act. - AT
Disallowance of deduction claimed u/s 10AA after claiming deduction / exemption u/s 10A - SEZ unit - As on the commencement of assessment year 2006-07, which is the effective date of operation of section 10AA, the unit has just claimed deduction under section 10A only for five assessment years and therefore, the assessee has submitted that the assessee company is entitled for deduction under section 10AA. - the assessee is entitled for deduction u/s 10AA(1)(ii) of the 1961 Act for the impugned assessment year, subject to fulfilment of other conditions for grant of deduction u/s 10AA of the 1961 Act. - AT
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