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...
TP adjustment - ALP of Contract Software Development (CSD Segment) - Comparable selection - The Tribunal upheld the exclusion of certain comparables based on functional dissimilarity with the assessee. However, it directed the Assessing Officer to re-examine the inclusion/exclusion criteria and the impact of amalgamation on profitability for certain comparables. - Regarding the issue of Adjustment of notional interest on overdue receivables from AEs: The Tribunal observed a pattern of intentional delays in payments to AEs, potentially benefiting them. However, it noted that the issue required further examination concerning the impact on working capital adjustment and the application of principles laid down by the jurisdictional High Court.
TP adjustment - ALP of Contract Software Development (CSD Segment) - Comparable selection - The Tribunal upheld the exclusion of certain comparables based on functional dissimilarity with the assessee. However, it directed the Assessing Officer to re-examine the inclusion/exclusion criteria and the impact of amalgamation on profitability for certain comparables. - Regarding the issue of Adjustment of notional interest on overdue receivables from AEs: The Tribunal observed a pattern of intentional delays in payments to AEs, potentially benefiting them. However, it noted that the issue required further examination concerning the impact on working capital adjustment and the application of principles laid down by the jurisdictional High Court.
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