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 u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in the current case, similar to the preceding assessment year, there was no proper recording of satisfaction by the AO for rejecting the suo moto disallowance made by the Assessee. As a result, the Tribunal allowed the Assessee's appeal and directed the AO to delete the impugned addition.
Disallowance u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in the current case, similar to the preceding assessment year, there was no proper recording of satisfaction by the AO for rejecting the suo moto disallowance made by the Assessee. As a result, the Tribunal allowed the Assessee's appeal and directed the AO to delete the impugned addition.
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