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...
Disallowance of carting expenses based on a presumed double claim was unsustainable where the assessee showed that transportation charges were raised separately by cement suppliers through debit notes or invoices, distinct from purchase invoices, and supported this with sample bills, vouchers and accounting records. The Tribunal held that the assessee's detailed explanation and documentary evidence had not been examined in either the assessment or appellate order, so the disallowance rested only on presumption and was vitiated. The addition was deleted and the assessee's appeal was allowed.
Disallowance of carting expenses based on a presumed double claim was unsustainable where the assessee showed that transportation charges were raised separately by cement suppliers through debit notes or invoices, distinct from purchase invoices, and supported this with sample bills, vouchers and accounting records. The Tribunal held that the assessee's detailed explanation and documentary evidence had not been examined in either the assessment or appellate order, so the disallowance rested only on presumption and was vitiated. The addition was deleted and the assessee's appeal was allowed.
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