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...
Grant of approval u/s 80G(5) - Delay in filing From No. 10AB for approval - final approval to be filled within a period of six months from date of grant of provisional registration - The Tribunal ultimately concluded that the discrepancies in deadlines between different sections were unreasonable and that a more lenient interpretation favoring the taxpayer should prevail. They remanded the matter back to the CIT for a re-decision, emphasizing a more equitable application of rules meant to facilitate charitable activities and donations.
Grant of approval u/s 80G(5) - Delay in filing From No. 10AB for approval - final approval to be filled within a period of six months from date of grant of provisional registration - The Tribunal ultimately concluded that the discrepancies in deadlines between different sections were unreasonable and that a more lenient interpretation favoring the taxpayer should prevail. They remanded the matter back to the CIT for a re-decision, emphasizing a more equitable application of rules meant to facilitate charitable activities and donations.
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