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...
A donor claiming weighted deduction for payment to an approved scientific research institution was held entitled to relief where the only basis for disallowance was uncorroborated third-party material about alleged wrongdoing by a donee employee. The Tribunal found that payment was made through banking channels, the donation was duly receipted, and approval under section 35(1)(ii) was on record. It held that the donor was not required to prove actual end-use of the funds once payment to an approved institution was established, and that alleged internal irregularities at the donee could not defeat the claim absent proof of nexus, complicity, sham, or return of funds. The disallowance was deleted.
A donor claiming weighted deduction for payment to an approved scientific research institution was held entitled to relief where the only basis for disallowance was uncorroborated third-party material about alleged wrongdoing by a donee employee. The Tribunal found that payment was made through banking channels, the donation was duly receipted, and approval under section 35(1)(ii) was on record. It held that the donor was not required to prove actual end-use of the funds once payment to an approved institution was established, and that alleged internal irregularities at the donee could not defeat the claim absent proof of nexus, complicity, sham, or return of funds. The disallowance was deleted.
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