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...
PCIT rightly invoked revisionary jurisdiction u/s 263 as AO failed to examine assessee's claim of depreciation on goodwill acquired through slump sale. ITAT upheld initiation of revisionary proceedings, set aside assessment order for limited adjudication on depreciation claim. AO directed to decide issue as per law after due verification whether transferor declared profits and paid taxes.
PCIT rightly invoked revisionary jurisdiction u/s 263 as AO failed to examine assessee's claim of depreciation on goodwill acquired through slump sale. ITAT upheld initiation of revisionary proceedings, set aside assessment order for limited adjudication on depreciation claim. AO directed to decide issue as per law after due verification whether transferor declared profits and paid taxes.
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