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...
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The Delhi High Court addressed the disallowance of provision for unsettled claims and Incurred But Not Reported (IBNR) Claims Reserve. The court held that the provision for outstanding claims can be allowed when materialized, not in the current year. The Tribunal's decision to delete the addition was justified as the provision was made based on claims lodged. The IBNR provisioning is regulated by the Insurance Regulatory and Development Authority of India Regulations, not considered a contingent liability. The court emphasized reasonable estimation and actuarial methods for liability quantification. The decision was against the revenue authority.
The Delhi High Court addressed the disallowance of provision for unsettled claims and Incurred But Not Reported (IBNR) Claims Reserve. The court held that the provision for outstanding claims can be allowed when materialized, not in the current year. The Tribunal's decision to delete the addition was justified as the provision was made based on claims lodged. The IBNR provisioning is regulated by the Insurance Regulatory and Development Authority of India Regulations, not considered a contingent liability. The court emphasized reasonable estimation and actuarial methods for liability quantification. The decision was against the revenue authority.
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