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...
The ITAT Delhi addressed the taxability of certain creditors as unexplained liabilities. It was found that liabilities of G.G.Telecrest Pvt. Ltd. and Uttam Strips Pvt. Ltd. should be classified as loans/advances, not creditors. The liabilities of these parties require further investigation. The issue was remitted back to the AO for reconsideration. For other creditors, where no details or confirmation were provided, the addition was upheld. Disallowance of commission expenses u/s 40(a)(ia) and taxability of cash deposits were also addressed, with the findings of the CIT(A) upheld due to lack of contradicting evidence. The appeal of the assessee was partly allowed.
The ITAT Delhi addressed the taxability of certain creditors as unexplained liabilities. It was found that liabilities of G.G.Telecrest Pvt. Ltd. and Uttam Strips Pvt. Ltd. should be classified as loans/advances, not creditors. The liabilities of these parties require further investigation. The issue was remitted back to the AO for reconsideration. For other creditors, where no details or confirmation were provided, the addition was upheld. Disallowance of commission expenses u/s 40(a)(ia) and taxability of cash deposits were also addressed, with the findings of the CIT(A) upheld due to lack of contradicting evidence. The appeal of the assessee was partly allowed.
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