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, an Appellate Tribunal, addressed the issue of determining income from futures transactions. The Tribunal held that the AO's addition lacked transparency as no information on the alleged transaction was shared. The CIT(A) accepted the turnover disclosed by the assessee but unreasonably applied a 50% profit rate. Given the acceptance of turnover and the assessee's choice of presumptive taxation u/s 44AD, the statutory 8% profit rate should apply. Consequently, the assessee's appeal was allowed.
The ITAT, an Appellate Tribunal, addressed the issue of determining income from futures transactions. The Tribunal held that the AO's addition lacked transparency as no information on the alleged transaction was shared. The CIT(A) accepted the turnover disclosed by the assessee but unreasonably applied a 50% profit rate. Given the acceptance of turnover and the assessee's choice of presumptive taxation u/s 44AD, the statutory 8% profit rate should apply. Consequently, the assessee's appeal was allowed.
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