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...
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
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