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...
Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
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