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...
Disallowance of expenditure owing to suspension of business operations - To our mind, not carrying on any business activities during a particular period cannot be equated with closure of business since it will lead to a narrow view of the scope of cessation of business. There is nothing on record to show that assessee has completely abandoned or closed the business forever by disposing of its assets and going into liquidation. - Appeal of the revenue dismissed - AT
Disallowance of expenditure owing to suspension of business operations - To our mind, not carrying on any business activities during a particular period cannot be equated with closure of business since it will lead to a narrow view of the scope of cessation of business. There is nothing on record to show that assessee has completely abandoned or closed the business forever by disposing of its assets and going into liquidation. - Appeal of the revenue dismissed - AT
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