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...
Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
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