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...
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
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