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...
Credit for withheld tax - Foreign Tax Credit - Both the parties below have recorded concurrent finding that the assessee company has not made any claim for credit towards the above stated withholding tax in earlier assessment years prior to the relevant assessment year 2014-15. We noted that the income has accrued in financial year 2013-14 relevant to assessment year 2014-15 and the assessee has correctly accounted this income in this very assessment year. Once the assessee has accounted for this income in this year and also claimed that tax credit, we are of the view that CIT(A) has rightly allowed the claim u/s.199 of the Act. - AT
Credit for withheld tax - Foreign Tax Credit - Both the parties below have recorded concurrent finding that the assessee company has not made any claim for credit towards the above stated withholding tax in earlier assessment years prior to the relevant assessment year 2014-15. We noted that the income has accrued in financial year 2013-14 relevant to assessment year 2014-15 and the assessee has correctly accounted this income in this very assessment year. Once the assessee has accounted for this income in this year and also claimed that tax credit, we are of the view that CIT(A) has rightly allowed the claim u/s.199 of the Act. - AT
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