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...
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
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