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...
Unexplained expenses u/s 69C - Discrepancy found in the payment of custom duty as per AIR [“Annual Information Report”] - Assessee failed to explain the reasons for variation and the SAD [“Special Additional Duty”] classified as current asset to be reflected in the P&L A/c at the stage of receipt of the funds/set off. - AT
Unexplained expenses u/s 69C - Discrepancy found in the payment of custom duty as per AIR [“Annual Information Report”] - Assessee failed to explain the reasons for variation and the SAD [“Special Additional Duty”] classified as current asset to be reflected in the P&L A/c at the stage of receipt of the funds/set off. - AT
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