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...
Disallowance of premium payable on redemption of debentures - addition on account of claim of premium on non-convertible debentures on proportionate basis - the moment the debentures were issued, the liability had arisen against the assessee which would constitute on expenditure allowable u/s 37 - Claim on proportionate basis cannot be disallowed - AT
Disallowance of premium payable on redemption of debentures - addition on account of claim of premium on non-convertible debentures on proportionate basis - the moment the debentures were issued, the liability had arisen against the assessee which would constitute on expenditure allowable u/s 37 - Claim on proportionate basis cannot be disallowed - AT
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