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...
Addition u/s 56(1) - shares received by the assessee company at the time of amalgamation - the Revenue is not precluded from ascertaining as to whether the scheme of amalgamation was in compliance with the provisions of the Act so as to avail the benefit of Section 47(vi) of the Act. - the scheme of amalgamation of EBPL with the assessee company cannot be disregarded nor can it be held to be a ‘colourable device’. - AT
Addition u/s 56(1) - shares received by the assessee company at the time of amalgamation - the Revenue is not precluded from ascertaining as to whether the scheme of amalgamation was in compliance with the provisions of the Act so as to avail the benefit of Section 47(vi) of the Act. - the scheme of amalgamation of EBPL with the assessee company cannot be disregarded nor can it be held to be a ‘colourable device’. - AT
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