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...
Income estimation based on percentage of gross receipts - CIT(A) applied 12.5% net profit on gross receipts, assessee claimed thin margins in advertisement business. ITAT held some guesswork inevitable without financial data. CIT(A) lacked material for 12.5%, assessee failed to substantiate lower 1.5-2% claim. Section 44AD deems 8% of turnover as business income for eligible assessees based on empirical data. Guided by equity, ITAT considered 8% of gross receipts fair estimation, modifying CIT(A)'s 12.5% to 8%. Assessee's appeal partly allowed.
Income estimation based on percentage of gross receipts - CIT(A) applied 12.5% net profit on gross receipts, assessee claimed thin margins in advertisement business. ITAT held some guesswork inevitable without financial data. CIT(A) lacked material for 12.5%, assessee failed to substantiate lower 1.5-2% claim. Section 44AD deems 8% of turnover as business income for eligible assessees based on empirical data. Guided by equity, ITAT considered 8% of gross receipts fair estimation, modifying CIT(A)'s 12.5% to 8%. Assessee's appeal partly allowed.
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