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...
Weighted deduction u/s 35(1)(ii) in respect of donations paid to one NGO - the modus operandi and non-genuineness of the donation was brought to light - Since, we held that the doctrine of fraud is applicable to the facts of the present case, even the principles of natural justice have no application, therefore, we uphold the orders of the lower authorities and dismiss the ground of appeal filed by the assessee. - AT
Weighted deduction u/s 35(1)(ii) in respect of donations paid to one NGO - the modus operandi and non-genuineness of the donation was brought to light - Since, we held that the doctrine of fraud is applicable to the facts of the present case, even the principles of natural justice have no application, therefore, we uphold the orders of the lower authorities and dismiss the ground of appeal filed by the assessee. - AT
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