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...
Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
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