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 held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
The ITAT held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
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