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...
Exemption claimed u/s.10(23B) - Mandatory approval from Khadi and Village Industries Commission - approval was granted for more than three assessment years and therefore the condition for claiming exemption u/s. 10(23B) was not fulfilled - It is pertinent to note that the time period for which the certificate has to be granted is not within the control of the assessee. In any case it is only a technical violation for which the assessee could not be penalized by denying the exemption otherwise allowable to the assessee. Thus, we hold that the assessee is entitled for exemption u/s. 10(23B) of the Act. - AT
Exemption claimed u/s.10(23B) - Mandatory approval from Khadi and Village Industries Commission - approval was granted for more than three assessment years and therefore the condition for claiming exemption u/s. 10(23B) was not fulfilled - It is pertinent to note that the time period for which the certificate has to be granted is not within the control of the assessee. In any case it is only a technical violation for which the assessee could not be penalized by denying the exemption otherwise allowable to the assessee. Thus, we hold that the assessee is entitled for exemption u/s. 10(23B) of the Act. - AT
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