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...
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Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a presumption can be drawn that the interest free loans and advances has been given by the assessee out of its own interest free fund available with it. Thus, in such a situation the disallowance of interest u/s 36(1)(iii) is not warranted. - AT
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