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...
Revision u/s 263 by CIT - Unexplained Cash deposited in the bank account - taxability of profit @ 8% u/s. 44AD - This action of the assessee was accepted by the AO without realising that provisions of section 44AD of the Act do not apply to a commission agent thereby making the assessment order erroneous in law and because of this error the AO did not examine the cash deposit making the assessment order pre judicial to the interest of the revenue. - AT
Revision u/s 263 by CIT - Unexplained Cash deposited in the bank account - taxability of profit @ 8% u/s. 44AD - This action of the assessee was accepted by the AO without realising that provisions of section 44AD of the Act do not apply to a commission agent thereby making the assessment order erroneous in law and because of this error the AO did not examine the cash deposit making the assessment order pre judicial to the interest of the revenue. - AT
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