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 on account of Capital Introduction - source of principal amount of FDRs - the constant effort made by the assessee to justify his stand that the credit is from maturity of old FDRs made by his aunt who was taken care of by the assessee only in the absence of her relative staying abroad which fact was also confirmed by other relatives of the assessee with supporting evidences as we have already discussed hereinabove, we find that the impugned addition made by the Department is of no basis and thus, deleted. - AT
Addition on account of Capital Introduction - source of principal amount of FDRs - the constant effort made by the assessee to justify his stand that the credit is from maturity of old FDRs made by his aunt who was taken care of by the assessee only in the absence of her relative staying abroad which fact was also confirmed by other relatives of the assessee with supporting evidences as we have already discussed hereinabove, we find that the impugned addition made by the Department is of no basis and thus, deleted. - AT
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