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...
The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
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