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...
Assessment u/s 153A - computation of income from house property. Additions proposed relate to unabated assessment years from 2013-14 onwards where no incriminating material found during search. Additions for 2013-14 and 2014-15 deleted as no incriminating evidence. For 2015-16 and 2016-17, incriminating emails found regarding commercial exploitation, hence additions upheld. Annual lettable value (ALV) capped at Rs. 8.39 lakhs based on 2016-17 as base year, 30% standard deduction allowed, net ALV of Rs. 5.87 lakhs taxable. Vatika Professional Point property never let out, additions deleted being unabated years without incriminating material. For Gurugram property, municipal value adopted as ALV instead of AO's estimate, as not commercially viable based on records. Where property not let out, ALV estimated at 5% of investment value as per judicial precedents, after standard deduction Rs. 6.65 lakhs added as income.
Assessment u/s 153A - computation of income from house property. Additions proposed relate to unabated assessment years from 2013-14 onwards where no incriminating material found during search. Additions for 2013-14 and 2014-15 deleted as no incriminating evidence. For 2015-16 and 2016-17, incriminating emails found regarding commercial exploitation, hence additions upheld. Annual lettable value (ALV) capped at Rs. 8.39 lakhs based on 2016-17 as base year, 30% standard deduction allowed, net ALV of Rs. 5.87 lakhs taxable. Vatika Professional Point property never let out, additions deleted being unabated years without incriminating material. For Gurugram property, municipal value adopted as ALV instead of AO's estimate, as not commercially viable based on records. Where property not let out, ALV estimated at 5% of investment value as per judicial precedents, after standard deduction Rs. 6.65 lakhs added as income.
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