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...
Addition on account of foreign currency found during the course of search - unaccounted income - The ITAT observed that no grounds to interfere with the CIT(A)'s findings. Despite acknowledging the possibility of the currency being remnants of business trips, the onus remained on the assessee to furnish conclusive evidence, which was not adequately provided. Consequently, the appeal of the assessee was dismissed.
Addition on account of foreign currency found during the course of search - unaccounted income - The ITAT observed that no grounds to interfere with the CIT(A)'s findings. Despite acknowledging the possibility of the currency being remnants of business trips, the onus remained on the assessee to furnish conclusive evidence, which was not adequately provided. Consequently, the appeal of the assessee was dismissed.
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