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...
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
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