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 case involved legality of assessment u/s 153A without search or Panchnama. The search warrant named the assessee company, rejecting the objection. No incriminating material was found during search, challenging the applicability of section 153A. Unexplained cash credit additions lacked proper investigation, leading to deletion of Rs. 3,70,000 addition. Income deposited in cash was declared and documented, leading to deletion of Rs. 10,50,000 addition. Addition u/s 68 was disputed, with relief granted by CIT(A). Disallowance of depreciation on vehicle was found baseless. CIT(A) upheld unexplained cash credit appeal, rejecting Department's challenge on genuineness. Overall, Department's appeal was dismissed due to lack of merit.
The case involved legality of assessment u/s 153A without search or Panchnama. The search warrant named the assessee company, rejecting the objection. No incriminating material was found during search, challenging the applicability of section 153A. Unexplained cash credit additions lacked proper investigation, leading to deletion of Rs. 3,70,000 addition. Income deposited in cash was declared and documented, leading to deletion of Rs. 10,50,000 addition. Addition u/s 68 was disputed, with relief granted by CIT(A). Disallowance of depreciation on vehicle was found baseless. CIT(A) upheld unexplained cash credit appeal, rejecting Department's challenge on genuineness. Overall, Department's appeal was dismissed due to lack of merit.
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