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...
Assessment of trust - Rectification of mistake u/s 154 - exemption u/s 80G/80GGA denied by CPC in 143(1) - The assessee had furnished relevant documents evidencing the donations made eligible for deduction under section 80GGA/80G of the Act. The same were not disputed by the Department. It is not a case where the assessee's donations were suspected or the institutions/funds to whom donations were made were under lens of suspicion, therefore, the observations made by CIT(A) for dismissing assessee's appeal are unsustainable. - AT
Assessment of trust - Rectification of mistake u/s 154 - exemption u/s 80G/80GGA denied by CPC in 143(1) - The assessee had furnished relevant documents evidencing the donations made eligible for deduction under section 80GGA/80G of the Act. The same were not disputed by the Department. It is not a case where the assessee's donations were suspected or the institutions/funds to whom donations were made were under lens of suspicion, therefore, the observations made by CIT(A) for dismissing assessee's appeal are unsustainable. - AT
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