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 Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
The Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
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