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...
Scope of “limited scrutiny”? - The purpose of selection of a case for scrutiny be it complete scrutiny or limited scrutiny, is only determination of total income of the assessee. In our considered opinion, this would certainly include determination of total income both under normal provisions of the Act as well as in the computation of book profits u/s.115JB of the Act. The ld. AO is bound to compute the total income under both the mechanisms provided under the Act and ultimately determine the higher of the two tax liabilities in the manner provided therein and raise a demand on the assessee. - AO had not travelled beyond the jurisdiction provided under the limited scrutiny by disturbing the computation of book profit u/s.115JB of the Act - AT
Scope of “limited scrutiny”? - The purpose of selection of a case for scrutiny be it complete scrutiny or limited scrutiny, is only determination of total income of the assessee. In our considered opinion, this would certainly include determination of total income both under normal provisions of the Act as well as in the computation of book profits u/s.115JB of the Act. The ld. AO is bound to compute the total income under both the mechanisms provided under the Act and ultimately determine the higher of the two tax liabilities in the manner provided therein and raise a demand on the assessee. - AO had not travelled beyond the jurisdiction provided under the limited scrutiny by disturbing the computation of book profit u/s.115JB of the Act - AT
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