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...
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
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