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 68 - bogus share application/allotment money - The Court noted the factual examination done by the Commissioner of Income Tax (Appeals) regarding the share capital of the companies involved. It found that the share capital raised by one of the companies in the assessment year 2009-10 had already been added back in the hands of the party, indicating its genuineness. The Court upheld the action of the Commissioner of Income Tax (Appeals) and ITAT in deleting the additions.
Addition u/s 68 - bogus share application/allotment money - The Court noted the factual examination done by the Commissioner of Income Tax (Appeals) regarding the share capital of the companies involved. It found that the share capital raised by one of the companies in the assessment year 2009-10 had already been added back in the hands of the party, indicating its genuineness. The Court upheld the action of the Commissioner of Income Tax (Appeals) and ITAT in deleting the additions.
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