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...
Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency for advances taken interest free from related parties. Assessee failed to substantiate commercial expediency for interest free advance to related party M/s. Diehard Dies Pvt. Limited. CIT(A) erred in considering transaction arose out of business/commercial expediency. Order of CIT(A) set aside, restoring AO's order. Revenue's appeal allowed.
Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency for advances taken interest free from related parties. Assessee failed to substantiate commercial expediency for interest free advance to related party M/s. Diehard Dies Pvt. Limited. CIT(A) erred in considering transaction arose out of business/commercial expediency. Order of CIT(A) set aside, restoring AO's order. Revenue's appeal allowed.
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