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...
Revision u/s 263 - ssessee has claimed foreign fluctuation loss with respect to foreign currency loan which was converted into the shares of the company - AO has not conducted inquiry with respect to loss claimed by the assessee in the revised return of income by virtue of amended provision of section 43AA of the Act which was made applicable retrospectively. - AT
Revision u/s 263 - ssessee has claimed foreign fluctuation loss with respect to foreign currency loan which was converted into the shares of the company - AO has not conducted inquiry with respect to loss claimed by the assessee in the revised return of income by virtue of amended provision of section 43AA of the Act which was made applicable retrospectively. - AT
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