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...
Excess stock found during survey in assessee's business premises led to surrendered income. Assessing Officer accepted return figures but applied higher tax rate u/s 115BBE, citing lack of stock register maintenance. Following precedents, it was held that surrendered income from excess stock during survey cannot be taxed u/s 69 deeming provisions. It should be assessed as business income at normal rates. Section 115BBE is inapplicable. Assessee's appeal allowed, and income to be charged at regular tax rates.
Excess stock found during survey in assessee's business premises led to surrendered income. Assessing Officer accepted return figures but applied higher tax rate u/s 115BBE, citing lack of stock register maintenance. Following precedents, it was held that surrendered income from excess stock during survey cannot be taxed u/s 69 deeming provisions. It should be assessed as business income at normal rates. Section 115BBE is inapplicable. Assessee's appeal allowed, and income to be charged at regular tax rates.
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