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...
Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
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