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...
Disallowance of Expenses - AO erred in appreciating that nonreply of Section 133(6) notices cannot necessarily lead to disallowance of petty expenses ranging from Rs. 9,000/- to Rs. 1,00,000/- in the absence of any other proof of non-incurring of expenses. Assessee has provided primary and direct evidences along with the PAN & address and hence, no disallowance can be made merely on the reason of noncompliance of the parties to the notices issued u/s 133(6) of the Act. - AT
Disallowance of Expenses - AO erred in appreciating that nonreply of Section 133(6) notices cannot necessarily lead to disallowance of petty expenses ranging from Rs. 9,000/- to Rs. 1,00,000/- in the absence of any other proof of non-incurring of expenses. Assessee has provided primary and direct evidences along with the PAN & address and hence, no disallowance can be made merely on the reason of noncompliance of the parties to the notices issued u/s 133(6) of the Act. - AT
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