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...
Demand u/s 201(1) with interest u/s 201(1A) - non deduction of TDS on the interest paid to HUDCO - minor delay in submitting the declaration that the payee (HUDCO) has paid tax on such interest - When there was no dispute about such a declaration being filed in a prescribed format and there was no dispute about the genuineness of such declaration, mere minor delay in filing the said declaration would not defeat the very claim. - AT
Demand u/s 201(1) with interest u/s 201(1A) - non deduction of TDS on the interest paid to HUDCO - minor delay in submitting the declaration that the payee (HUDCO) has paid tax on such interest - When there was no dispute about such a declaration being filed in a prescribed format and there was no dispute about the genuineness of such declaration, mere minor delay in filing the said declaration would not defeat the very claim. - AT
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