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...
Disallowance of bad debts written off - bad debts in respect of subscriptions defaulted by the prized subscribers - The Tribunal found the CIT(A)'s decision well-founded, particularly in light of the specific judicial pronouncements and the ITAT Hyderabad's stance, which had, in principle, allowed the claim of bad debts related to chit funds while remanding the matter for factual verification. Moreover, the Tribunal noted that the relationship between chit fund transactions did not characterize a typical debtor-creditor scenario, aligning with the principles laid out in significant judgments.
Disallowance of bad debts written off - bad debts in respect of subscriptions defaulted by the prized subscribers - The Tribunal found the CIT(A)'s decision well-founded, particularly in light of the specific judicial pronouncements and the ITAT Hyderabad's stance, which had, in principle, allowed the claim of bad debts related to chit funds while remanding the matter for factual verification. Moreover, the Tribunal noted that the relationship between chit fund transactions did not characterize a typical debtor-creditor scenario, aligning with the principles laid out in significant judgments.
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