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 69C - bogus purchase bills - AO was having complete information about those parties - The ld. AO himself made any enquiry with those parties further with respect to genuineness of purchase of material by the assessee. - The only allegation of the assessing officer is that assessee has failed to show receipt of goods as well as failed to produce those parties. Furthermore, looking to the nature of the business, assessee cannot be asked to produce more details then what is generally kept by an assessee in that line of the business. - AT
Addition u/s 69C - bogus purchase bills - AO was having complete information about those parties - The ld. AO himself made any enquiry with those parties further with respect to genuineness of purchase of material by the assessee. - The only allegation of the assessing officer is that assessee has failed to show receipt of goods as well as failed to produce those parties. Furthermore, looking to the nature of the business, assessee cannot be asked to produce more details then what is generally kept by an assessee in that line of the business. - AT
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