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...
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
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