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...
Interest earned on fixed deposits kept only to furnish a bank guarantee for the project was held to have an inextricable nexus with the project and, therefore, had to be capitalised to work-in-progress rather than taxed as income from other sources. The Tribunal found the deposits were not a deployment of surplus funds, the bank guarantee remained in force during the relevant year, and the project had not finally ceased because cancellation was still under challenge. On that basis, it applied the project-linked receipt principle and distinguished Tuticorin Alkali, deleting the addition.
Interest earned on fixed deposits kept only to furnish a bank guarantee for the project was held to have an inextricable nexus with the project and, therefore, had to be capitalised to work-in-progress rather than taxed as income from other sources. The Tribunal found the deposits were not a deployment of surplus funds, the bank guarantee remained in force during the relevant year, and the project had not finally ceased because cancellation was still under challenge. On that basis, it applied the project-linked receipt principle and distinguished Tuticorin Alkali, deleting the addition.
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