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 validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
The ITAT Delhi addressed the validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
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