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...
After the 01-04-2016 amendment, weighted deduction for in-house R&D under section 35(2AB) was confined to the expenditure quantified by the DSIR in Form 3CL, and the Assessing Officer could not allow a higher amount. MEIS receipts treated as capital receipts were not liable to addition in book profit under section 115JB unless they fell within the specific Explanation 1 adjustments, and a capital receipt not debited to profit and loss could not be added merely because of accounting treatment. Loss on investment in a wholly owned subsidiary was treated as business loss where the investment was made on commercial expediency to further business operations. Both the assessee's and Revenue's appeals were dismissed.
After the 01-04-2016 amendment, weighted deduction for in-house R&D under section 35(2AB) was confined to the expenditure quantified by the DSIR in Form 3CL, and the Assessing Officer could not allow a higher amount. MEIS receipts treated as capital receipts were not liable to addition in book profit under section 115JB unless they fell within the specific Explanation 1 adjustments, and a capital receipt not debited to profit and loss could not be added merely because of accounting treatment. Loss on investment in a wholly owned subsidiary was treated as business loss where the investment was made on commercial expediency to further business operations. Both the assessee's and Revenue's appeals were dismissed.
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