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...
MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
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