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...
Credit of Dividend Distribution Tax u/s 115-O - The AO, in preparing the statement of assessed total income, computed the DDT payable but did not adjust the DDT already paid by the assessee, effectively showing it as payable. - the Revenue has denied the credit based on the misunderstood fact that the assessee is claiming credit for the Dividend Distribution Tax against regular tax payable. This in our considered view is factually incorrect, since the assessee is seeking to adjust the Dividend Distribution Tax paid against the Dividend Distribution Tax payable computed by the AO. - Adjustment of credit allowed - AT
Credit of Dividend Distribution Tax u/s 115-O - The AO, in preparing the statement of assessed total income, computed the DDT payable but did not adjust the DDT already paid by the assessee, effectively showing it as payable. - the Revenue has denied the credit based on the misunderstood fact that the assessee is claiming credit for the Dividend Distribution Tax against regular tax payable. This in our considered view is factually incorrect, since the assessee is seeking to adjust the Dividend Distribution Tax paid against the Dividend Distribution Tax payable computed by the AO. - Adjustment of credit allowed - AT
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