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 adjudicated a dispute regarding tax assessment in a precious metal business. The tribunal found the Assessing Officer (AO) improperly rejected audited books under Section 145(3) without conducting a mandatory special audit under Section 142(2A). The ad-hoc income determination was deemed capricious and irrational, lacking cogent material and expert assessment. Given the complex business nature involving high-value transactions and inventory volatility, the tribunal disapproved the arbitrary income estimation. The matter was remanded to the AO for fresh income determination in strict compliance with legal provisions, with the appeal allowed for statistical purposes.
ITAT adjudicated a dispute regarding tax assessment in a precious metal business. The tribunal found the Assessing Officer (AO) improperly rejected audited books under Section 145(3) without conducting a mandatory special audit under Section 142(2A). The ad-hoc income determination was deemed capricious and irrational, lacking cogent material and expert assessment. Given the complex business nature involving high-value transactions and inventory volatility, the tribunal disapproved the arbitrary income estimation. The matter was remanded to the AO for fresh income determination in strict compliance with legal provisions, with the appeal allowed for statistical purposes.
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