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...
Unexplained jewellery could not be added where the assessee produced a detailed break-up of ornaments, family-wise allocation, affidavits for gifts on marriage and other occasions, supporting bills, and bank withdrawals showing purchases. CBDT Instruction No. 1916 and the precedent in Vibhu Aggarwal were applied to recognise reasonable family holding of jewellery having regard to status, customs, and customary occasions, so the Assessing Officer's addition was deleted.
Unexplained jewellery could not be added where the assessee produced a detailed break-up of ornaments, family-wise allocation, affidavits for gifts on marriage and other occasions, supporting bills, and bank withdrawals showing purchases. CBDT Instruction No. 1916 and the precedent in Vibhu Aggarwal were applied to recognise reasonable family holding of jewellery having regard to status, customs, and customary occasions, so the Assessing Officer's addition was deleted.
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