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 towards difference between the rental income received by the assessee from M/s.CFD, a partnership firm and rental income received by the partnership firm, M/s.CFD from three tenants - The tribunal sided with the trust, ruling that the Assessing Officer erred in attributing additional rental income to the trust, as the sub-leases were based on substantial enhancements made by the lessee, justifying higher rents from sub-tenants.
Addition towards difference between the rental income received by the assessee from M/s.CFD, a partnership firm and rental income received by the partnership firm, M/s.CFD from three tenants - The tribunal sided with the trust, ruling that the Assessing Officer erred in attributing additional rental income to the trust, as the sub-leases were based on substantial enhancements made by the lessee, justifying higher rents from sub-tenants.
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