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 assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
The assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
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