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...
Rectification u/s 154 - Exemption u/s 11(2) - Accumulation of income - The Appellate Tribunal found merit in the appellant's contention regarding the amount to be accumulated under section 11(2) of the Act. - It was established that the appellant had accumulated Rs. 110,94,73,718/- in the specified modes under section 11(5) of the Act, which was lower than the required accumulation of Rs. 120,00,31,900/-. - Therefore, the deduction under section 11(2) was allowable only on the amount accumulated, resulting in a partial allowance of the claim.
Rectification u/s 154 - Exemption u/s 11(2) - Accumulation of income - The Appellate Tribunal found merit in the appellant's contention regarding the amount to be accumulated under section 11(2) of the Act. - It was established that the appellant had accumulated Rs. 110,94,73,718/- in the specified modes under section 11(5) of the Act, which was lower than the required accumulation of Rs. 120,00,31,900/-. - Therefore, the deduction under section 11(2) was allowable only on the amount accumulated, resulting in a partial allowance of the claim.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
