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 challenged the addition made u/s 69A for non-payment of advance tax, claiming the assessment proceedings were initiated based on wrong information. The Tribunal, being the final fact-finding authority, examined the material and found that the Assessing Officer erroneously initiated proceedings u/s 148, assuming the assessee had purchased an immovable property for Rs. 45 lakhs from Shri Madhava Gatti. However, the assessee produced the sale deed showing the purchase was from Mr. Madhava Gatti for Rs. 31 lakhs and provided the source of funds as a loan from Vijaya Bank. Consequently, the Tribunal held that the basis for the addition did not survive and deleted the addition made by the Assessing Officer u/s 69A, allowing the assessee's appeal.
The assessee challenged the addition made u/s 69A for non-payment of advance tax, claiming the assessment proceedings were initiated based on wrong information. The Tribunal, being the final fact-finding authority, examined the material and found that the Assessing Officer erroneously initiated proceedings u/s 148, assuming the assessee had purchased an immovable property for Rs. 45 lakhs from Shri Madhava Gatti. However, the assessee produced the sale deed showing the purchase was from Mr. Madhava Gatti for Rs. 31 lakhs and provided the source of funds as a loan from Vijaya Bank. Consequently, the Tribunal held that the basis for the addition did not survive and deleted the addition made by the Assessing Officer u/s 69A, allowing the assessee's appeal.
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