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 High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
The High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
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