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...
Genuineness of expenditure - CIT(A) deleted the additions - CIT(A) went into detail to evaluate the identity of commission recipient and genuineness of expenditure of all recipient entities and thereafter, drawn party wise conclusion and directed the AO to delete the entire addition made by the Assessing Officer on account of brokerage of commission paid to the various brokers. The conclusion drawn by the ld. CIT(A) is based on proper appreciation of facts. - AT
Genuineness of expenditure - CIT(A) deleted the additions - CIT(A) went into detail to evaluate the identity of commission recipient and genuineness of expenditure of all recipient entities and thereafter, drawn party wise conclusion and directed the AO to delete the entire addition made by the Assessing Officer on account of brokerage of commission paid to the various brokers. The conclusion drawn by the ld. CIT(A) is based on proper appreciation of facts. - AT
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