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...
Adjustment made in the intimation u/s. 143(1) - denying the benefit of deduction/exemption u/s 11 - CIT(A)'s order, justifying the adjustments on the basis of disclosure made by the assessee that it was not registered as a charitable entity, is we find taking a hyper technical view on the issue, particularly when the adjustment was made without affording any opportunity to the assessee as provided in law, coupled with the fact that the assessee had evidenced its registration u/s. 12A of the Act to the Ld. CIT(A) by producing the certificate. Also the Ld. CIT(A) has not addressed the alternative argument of the assessee that even after the adjustments its income was below the taxable limit. - AT
Adjustment made in the intimation u/s. 143(1) - denying the benefit of deduction/exemption u/s 11 - CIT(A)'s order, justifying the adjustments on the basis of disclosure made by the assessee that it was not registered as a charitable entity, is we find taking a hyper technical view on the issue, particularly when the adjustment was made without affording any opportunity to the assessee as provided in law, coupled with the fact that the assessee had evidenced its registration u/s. 12A of the Act to the Ld. CIT(A) by producing the certificate. Also the Ld. CIT(A) has not addressed the alternative argument of the assessee that even after the adjustments its income was below the taxable limit. - AT
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