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 under the head of Vehicle Running Expenses and Repairs & Maintenance - "exaggerated expense' or "not reasonable expense". - The onus is on the Revenue to establish that the expenses claimed by the assessee has been booked twice in the books of accounts. However, the Revenue has not brought in any evidence - the claim of the assessee on account of vehicle running expenses on account of repairs & maintenance expense deserves to be allowed. - AT
Addition under the head of Vehicle Running Expenses and Repairs & Maintenance - "exaggerated expense' or "not reasonable expense". - The onus is on the Revenue to establish that the expenses claimed by the assessee has been booked twice in the books of accounts. However, the Revenue has not brought in any evidence - the claim of the assessee on account of vehicle running expenses on account of repairs & maintenance expense deserves to be allowed. - AT
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