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 Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions.
The Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions.
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