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...
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
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