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...
Computation of deduction u/ss 80IB/80IC and 10B - AO allocated Head Office expenses to eligible units, reducing deduction. Tribunal consistently restores issue with directions to allocate common expenses and income to eligible units. Miscellaneous income from sale of scraps/by-products in eligible units held eligible for deduction. Adjustment for CENVAT credit u/s 145A - issue restored to AO to examine assessee's claim. Expenditure on relief materials for Tsunami victims disallowed as not wholly and exclusively for business u/s 37(1), not allowable as sales promotion or CSR expenses. Insurance claim amount to be added to WDV, not treated as capital receipt. Capital subsidy not to be reduced from WDV for depreciation. Rate of tax on dividend to non-residents decided against assessee by Special Bench. Transfer pricing adjustment at entity level under TNMM accepted following earlier year order.
Computation of deduction u/ss 80IB/80IC and 10B - AO allocated Head Office expenses to eligible units, reducing deduction. Tribunal consistently restores issue with directions to allocate common expenses and income to eligible units. Miscellaneous income from sale of scraps/by-products in eligible units held eligible for deduction. Adjustment for CENVAT credit u/s 145A - issue restored to AO to examine assessee's claim. Expenditure on relief materials for Tsunami victims disallowed as not wholly and exclusively for business u/s 37(1), not allowable as sales promotion or CSR expenses. Insurance claim amount to be added to WDV, not treated as capital receipt. Capital subsidy not to be reduced from WDV for depreciation. Rate of tax on dividend to non-residents decided against assessee by Special Bench. Transfer pricing adjustment at entity level under TNMM accepted following earlier year order.
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