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...
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The Appellate Tribunal held in favor of the assessee regarding addition towards prior period expenses, citing consistency in previous rulings and emphasizing the assessing officer's obligation to consider the status as a whole. The Tribunal rejected the disallowance u/s 40(a)(ia) for demurrage charges, noting the nature of payments to foreign shipping companies and applicability of relevant Board Circular. TDS credit was denied initially due to non-inclusion in Form-26AS, but the Tribunal referred to CBDT Circular allowing credit based on original Form-16A submission, directing verification by the assessing officer. The Tribunal upheld the charging of interest u/s 234C, citing the lack of provision for waiver despite financial restructuring.
The Appellate Tribunal held in favor of the assessee regarding addition towards prior period expenses, citing consistency in previous rulings and emphasizing the assessing officer's obligation to consider the status as a whole. The Tribunal rejected the disallowance u/s 40(a)(ia) for demurrage charges, noting the nature of payments to foreign shipping companies and applicability of relevant Board Circular. TDS credit was denied initially due to non-inclusion in Form-26AS, but the Tribunal referred to CBDT Circular allowing credit based on original Form-16A submission, directing verification by the assessing officer. The Tribunal upheld the charging of interest u/s 234C, citing the lack of provision for waiver despite financial restructuring.
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