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...
Addition u/s 68 - unexplained credits - The provisions of Section 68 of the Act are attracted in case of unexplained credits during the relevant previous year. Since the outstanding loan/liability pertaining to BMPL and pertaining to SSL represent credits of earlier years, provisions of Section 68 would not be attracted in the facts and circumstances of the present case. - AT
Addition u/s 68 - unexplained credits - The provisions of Section 68 of the Act are attracted in case of unexplained credits during the relevant previous year. Since the outstanding loan/liability pertaining to BMPL and pertaining to SSL represent credits of earlier years, provisions of Section 68 would not be attracted in the facts and circumstances of the present case. - AT
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