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 held that disallowance of advertisement expenses lacked merit as the charges were reasonable. The 15% discount received by the agent did not impact the reasonableness of charges borne by the assessee. However, hoarding expenses lacked substantiation, requiring further verification. The matter was remanded to the AO for review. Similarly, addition on commission and brokerage expenses needed reevaluation with proper substantiation. The AO's disallowance of depreciation on fixed assets was overturned as the assessee was entitled to claim depreciation under section 32 of the Act.
The ITAT held that disallowance of advertisement expenses lacked merit as the charges were reasonable. The 15% discount received by the agent did not impact the reasonableness of charges borne by the assessee. However, hoarding expenses lacked substantiation, requiring further verification. The matter was remanded to the AO for review. Similarly, addition on commission and brokerage expenses needed reevaluation with proper substantiation. The AO's disallowance of depreciation on fixed assets was overturned as the assessee was entitled to claim depreciation under section 32 of the Act.
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