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...
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
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