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...
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
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