Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
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