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...
Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
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