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...
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
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