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 foreign tax credits - failure to the requisite documents as specified u/s 128(8) - Considering the fact that the assessee is stated to be in possession of documentary evidence, as required under rule 128(8) and (9), we direct the assessee to furnish them before AO for examination. AO is directed to verify the documentary evidences filed or to be filed by the assessee and allow foreign tax credit in accordance with the extant rules read with section 90 of the Act. - AT
Disallowance of foreign tax credits - failure to the requisite documents as specified u/s 128(8) - Considering the fact that the assessee is stated to be in possession of documentary evidence, as required under rule 128(8) and (9), we direct the assessee to furnish them before AO for examination. AO is directed to verify the documentary evidences filed or to be filed by the assessee and allow foreign tax credit in accordance with the extant rules read with section 90 of the Act. - AT
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