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 of On-money receipts - addition based on the documents impounded during the survey proceedings - The ld CIT(A) concluded that the documents are dumb documents so far as assessee is concern. - CIT(A) categorically held that assessee sold the unit / shops to Mahotsav group about 28% higher that the prevailing jantri rate and there is no concrete evidence against the assessee either on writing or oral which establish that the assessee received alleged on money. - The order of CIT (A), deleting the additions confirmed - AT
Addition of On-money receipts - addition based on the documents impounded during the survey proceedings - The ld CIT(A) concluded that the documents are dumb documents so far as assessee is concern. - CIT(A) categorically held that assessee sold the unit / shops to Mahotsav group about 28% higher that the prevailing jantri rate and there is no concrete evidence against the assessee either on writing or oral which establish that the assessee received alleged on money. - The order of CIT (A), deleting the additions confirmed - AT
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