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...
Uncorroborated retracted search statements, third-party tally data and WhatsApp material were found insufficient to sustain alleged commission additions in the individual assessee's case, because there was no cash trail, bank entry or independent documentary proof of receipt; the additions were deleted. Reassessment notices issued beyond three years were held invalid where section 149(1)(b) was not satisfied, as the alleged escapement did not meet the Rs. 50 lakh threshold; the reassessment proceedings were quashed. In the company's case, alleged cash-sales and commission-expenditure issues were remanded for fresh adjudication because factual verification and 65B compliance were required.
Uncorroborated retracted search statements, third-party tally data and WhatsApp material were found insufficient to sustain alleged commission additions in the individual assessee's case, because there was no cash trail, bank entry or independent documentary proof of receipt; the additions were deleted. Reassessment notices issued beyond three years were held invalid where section 149(1)(b) was not satisfied, as the alleged escapement did not meet the Rs. 50 lakh threshold; the reassessment proceedings were quashed. In the company's case, alleged cash-sales and commission-expenditure issues were remanded for fresh adjudication because factual verification and 65B compliance were required.
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