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)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
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