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...
A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
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