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...
In the absence of incriminating material found during the search u/s 153A, no addition can be made for the assessment year 2012-13, except supported by incriminating documents. This view finds support from the Supreme Court's judgment in PCIT vs. Abhisar Buildwell P. Ltd., wherein it was held that no addition can be made for completed assessments without incriminating material. Further, the Rajasthan High Court's decision in PCIT vs. M/s. Esspal International P. Ltd. stated that merely based on a retracted statement, no addition can be sustained. Consequently, the addition was directed to be deleted, deciding in favor of the assessee.
In the absence of incriminating material found during the search u/s 153A, no addition can be made for the assessment year 2012-13, except supported by incriminating documents. This view finds support from the Supreme Court's judgment in PCIT vs. Abhisar Buildwell P. Ltd., wherein it was held that no addition can be made for completed assessments without incriminating material. Further, the Rajasthan High Court's decision in PCIT vs. M/s. Esspal International P. Ltd. stated that merely based on a retracted statement, no addition can be sustained. Consequently, the addition was directed to be deleted, deciding in favor of the assessee.
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