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...
Unexplained cash credit u/s 68 - share capital/share premium receipts - Despite substantial evidence provided by the appellant, including bank statements, share allotment documents, and resolutions of the board of directors, the AO failed to conduct further investigation, particularly after being informed of the change in the registered office address of the investing company. The Tribunal notes the reliance by the AO on the non-production of directors of the investing company for making the addition, without adequately considering the evidence provided by the appellant. - Additions directed to be deleted.
Unexplained cash credit u/s 68 - share capital/share premium receipts - Despite substantial evidence provided by the appellant, including bank statements, share allotment documents, and resolutions of the board of directors, the AO failed to conduct further investigation, particularly after being informed of the change in the registered office address of the investing company. The Tribunal notes the reliance by the AO on the non-production of directors of the investing company for making the addition, without adequately considering the evidence provided by the appellant. - Additions directed to be deleted.
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