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...
Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
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