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...
The ITAT ruled in favor of the assessee on the following issues: 1. Addition u/s 68 for refund of advances received from different parties was deleted. The ITAT held that receiving refunds through banking channels from different parties than those to whom advances were given earlier cannot be the sole ground for addition u/s 68, especially when the assessee had provided complete details and confirmations from the parties. The AO should have conducted further investigation if doubts persisted. 2. Disallowance of depreciation on capital assets purchased from a party involved in accommodation entries was rejected. The ITAT accepted the assessee's contention that the assets were installed, commissioned, and put to use, and the AO should have conducted physical verification when requested instead of disallowing depreciation. 3. Consequently, the penalty u/s 271(1)(c) related to the disallowed depreciation claim was also deleted.
The ITAT ruled in favor of the assessee on the following issues: 1. Addition u/s 68 for refund of advances received from different parties was deleted. The ITAT held that receiving refunds through banking channels from different parties than those to whom advances were given earlier cannot be the sole ground for addition u/s 68, especially when the assessee had provided complete details and confirmations from the parties. The AO should have conducted further investigation if doubts persisted. 2. Disallowance of depreciation on capital assets purchased from a party involved in accommodation entries was rejected. The ITAT accepted the assessee's contention that the assets were installed, commissioned, and put to use, and the AO should have conducted physical verification when requested instead of disallowing depreciation. 3. Consequently, the penalty u/s 271(1)(c) related to the disallowed depreciation claim was also deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
