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...
The ITAT upheld the CIT(A)'s order rejecting the assessee's books of accounts and estimating total income. When books are rejected u/s 145 and income estimated u/s 144, the estimate substitutes business income computed u/ss 30-43D. All deductions u/ss 30-43D are deemed considered in the estimate. The ITAT found no infirmity in rejecting books and estimating income.
The ITAT upheld the CIT(A)'s order rejecting the assessee's books of accounts and estimating total income. When books are rejected u/s 145 and income estimated u/s 144, the estimate substitutes business income computed u/ss 30-43D. All deductions u/ss 30-43D are deemed considered in the estimate. The ITAT found no infirmity in rejecting books and estimating income.
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