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 two key issues. Firstly, on disallowance of provision for leave encashment, the AO rejected the claim as it was not made through a revised return. The Tribunal held that deduction can only be allowed when actual payment is made u/s 43B(f) of the Act, citing a Supreme Court ruling. AO directed to verify actual payment date. Secondly, on taxability of excise duty subsidy, the Tribunal ruled it as capital receipt based on earlier decisions, holding it non-taxable. Additional ground raised by the assessee was allowed.
The ITAT Delhi addressed two key issues. Firstly, on disallowance of provision for leave encashment, the AO rejected the claim as it was not made through a revised return. The Tribunal held that deduction can only be allowed when actual payment is made u/s 43B(f) of the Act, citing a Supreme Court ruling. AO directed to verify actual payment date. Secondly, on taxability of excise duty subsidy, the Tribunal ruled it as capital receipt based on earlier decisions, holding it non-taxable. Additional ground raised by the assessee was allowed.
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