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...
CIT(A) restricted addition on account of accommodation entries to 15% instead of 100%, as the Assessing Officer failed to establish that work was not actually performed. The Tribunal concurred with CIT(A)'s disallowance rate of 15% and rejected Revenue's contention to restore 100% disallowance. Regarding commission expenses of INR 8,81,3000/-, the Tribunal upheld CIT(A)'s deletion in the absence of material to substantiate the allegation of 1% commission payment. CIT(A) correctly allowed the claim of deduction u/s 80-IA based on the Assessing Officer's remand report. Concerning disallowance u/s 14A, the Tribunal upheld CIT(A)'s findings as the assessee had suo moto disallowed a higher amount of 1% of average investment as administrative expenses compared to the Assessing Officer's disallowance of 0.5%. The Tribunal dismissed the Revenue's grounds on all issues.
CIT(A) restricted addition on account of accommodation entries to 15% instead of 100%, as the Assessing Officer failed to establish that work was not actually performed. The Tribunal concurred with CIT(A)'s disallowance rate of 15% and rejected Revenue's contention to restore 100% disallowance. Regarding commission expenses of INR 8,81,3000/-, the Tribunal upheld CIT(A)'s deletion in the absence of material to substantiate the allegation of 1% commission payment. CIT(A) correctly allowed the claim of deduction u/s 80-IA based on the Assessing Officer's remand report. Concerning disallowance u/s 14A, the Tribunal upheld CIT(A)'s findings as the assessee had suo moto disallowed a higher amount of 1% of average investment as administrative expenses compared to the Assessing Officer's disallowance of 0.5%. The Tribunal dismissed the Revenue's grounds on all issues.
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