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...
Addition u/s 56(2)(x) - sale of flats - difference between the value taken by the assessee and the fair market value (FMV) u/s 50C - The ITAT found that the value adopted by the assessee and the FMV of the flats under Section 50C were within the range of ±10%, thus the provisions of Section 56(2)(x) did not apply. - Following the earlier decisions, the Tribunal deleted the additions.
Addition u/s 56(2)(x) - sale of flats - difference between the value taken by the assessee and the fair market value (FMV) u/s 50C - The ITAT found that the value adopted by the assessee and the FMV of the flats under Section 50C were within the range of ±10%, thus the provisions of Section 56(2)(x) did not apply. - Following the earlier decisions, the Tribunal deleted the additions.
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