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...
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
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