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...
Revision u/s 263 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
Revision u/s 263 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
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