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...
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
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