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 adjudicated a tax dispute involving circular trading and salary expenses. The tribunal found no substantive evidence to support the Assessing Officer's (AO) arbitrary addition of commission income. The AO's estimate of 3% on sales and purchases was deemed unwarranted, as no specific allegation of commission payment was established in KGR Enterprises' assessment order. Similarly, the adhoc addition under salary and wages was deleted, as the expenses were commensurate with business turnover and no specific defects were identified in the documentation. The tribunal ultimately rejected both proposed additions, providing relief to the assessee by eliminating the unsupported tax adjustments.
ITAT adjudicated a tax dispute involving circular trading and salary expenses. The tribunal found no substantive evidence to support the Assessing Officer's (AO) arbitrary addition of commission income. The AO's estimate of 3% on sales and purchases was deemed unwarranted, as no specific allegation of commission payment was established in KGR Enterprises' assessment order. Similarly, the adhoc addition under salary and wages was deleted, as the expenses were commensurate with business turnover and no specific defects were identified in the documentation. The tribunal ultimately rejected both proposed additions, providing relief to the assessee by eliminating the unsupported tax adjustments.
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