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...
Valuation - inclusion of advertisement and publicity expenses incurred by the dealers as per the terms and conditions of the dealership agreement mutually agreed between the appellant and their dealers, in the assessable value of the vehicles sold by the appellant - The Tribunal found that the dealership agreement did not impose an enforceable right on the appellant to require dealers to incur specific advertisement expenses. It concluded that since the expenses were incurred at the dealers' discretion and the sale price of vehicles to dealers was unaffected by whether dealers chose to advertise, such expenses should not be included in the assessable value.
Valuation - inclusion of advertisement and publicity expenses incurred by the dealers as per the terms and conditions of the dealership agreement mutually agreed between the appellant and their dealers, in the assessable value of the vehicles sold by the appellant - The Tribunal found that the dealership agreement did not impose an enforceable right on the appellant to require dealers to incur specific advertisement expenses. It concluded that since the expenses were incurred at the dealers' discretion and the sale price of vehicles to dealers was unaffected by whether dealers chose to advertise, such expenses should not be included in the assessable value.
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