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...
Disallowance of commission paid to foreign agents - The Tribunal upheld the disallowance of commission expenses to both domestic and non-resident companies due to the lack of evidence of services provided and non-compliance with TDS requirements. Similarly, the disallowance of legal and professional charges was upheld as the services originated from India. Additionally, the Tribunal upheld the disallowance of interest expenses, noting the diversion of interest-bearing funds for non-business purposes
Disallowance of commission paid to foreign agents - The Tribunal upheld the disallowance of commission expenses to both domestic and non-resident companies due to the lack of evidence of services provided and non-compliance with TDS requirements. Similarly, the disallowance of legal and professional charges was upheld as the services originated from India. Additionally, the Tribunal upheld the disallowance of interest expenses, noting the diversion of interest-bearing funds for non-business purposes
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