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 on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
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