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) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
Addition u/s 56(2) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
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