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...
ITAT admitted additional ground regarding exemption under s.10(15)(iv)(h) for interest income from PSU bonds/debentures, following NTPC precedent and Bombay HC ruling in Siva Equipment. Matter remanded to AO for verification of eligibility criteria. On s.80G deduction claim, following previous ITAT ruling for AY 2006-07, issue remanded to AO for fresh examination. Regarding computation u/r 2 of First Schedule (s.44), ITAT affirmed that life insurance business profits must be calculated as annual average surplus between inter-valuation periods per Insurance Act 1938 requirements. Revenue's appeal dismissed on all grounds, maintaining consistency with prior coordinate bench decisions. AO directed to verify factual aspects of exemption claims while adhering to statutory provisions.
ITAT admitted additional ground regarding exemption under s.10(15)(iv)(h) for interest income from PSU bonds/debentures, following NTPC precedent and Bombay HC ruling in Siva Equipment. Matter remanded to AO for verification of eligibility criteria. On s.80G deduction claim, following previous ITAT ruling for AY 2006-07, issue remanded to AO for fresh examination. Regarding computation u/r 2 of First Schedule (s.44), ITAT affirmed that life insurance business profits must be calculated as annual average surplus between inter-valuation periods per Insurance Act 1938 requirements. Revenue's appeal dismissed on all grounds, maintaining consistency with prior coordinate bench decisions. AO directed to verify factual aspects of exemption claims while adhering to statutory provisions.
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