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 addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
The ITAT addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
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