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...
Ad hoc disallowance of alleged bogus purchases was held unsustainable where purchases were recorded, paid through banking channels and supported by invoices, transport records and stock data, and the books were not rejected. Warranty expenditure was allowed on the basis of consistent accounting treatment, business nexus and absence of incriminating material. Commission expenditure was also allowed because payments were banked, tax was deducted at source and the same disallowance had earlier been deleted without further challenge. In search-related reassessment, the special statutory route prevailed over general scrutiny assessment, and non-compliance with the mandatory procedure rendered the assessments without jurisdiction. Cash found during search could not be telescoped against unaccounted sales, but excess finished stock was telescoped against undisclosed business income.
Ad hoc disallowance of alleged bogus purchases was held unsustainable where purchases were recorded, paid through banking channels and supported by invoices, transport records and stock data, and the books were not rejected. Warranty expenditure was allowed on the basis of consistent accounting treatment, business nexus and absence of incriminating material. Commission expenditure was also allowed because payments were banked, tax was deducted at source and the same disallowance had earlier been deleted without further challenge. In search-related reassessment, the special statutory route prevailed over general scrutiny assessment, and non-compliance with the mandatory procedure rendered the assessments without jurisdiction. Cash found during search could not be telescoped against unaccounted sales, but excess finished stock was telescoped against undisclosed business income.
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