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...
In a limited scrutiny assessment selected through CASS, the Assessing Officer is confined to the specific issues for which scrutiny was initiated. Enquiry into matters outside those issues is permissible only after conversion into complete scrutiny with the prescribed approval. Because the addition was made beyond the selected scrutiny scope and no valid conversion was shown, the Tribunal held that the assessment had travelled beyond jurisdiction and the addition was unsustainable. The assessee's appeal was allowed.
In a limited scrutiny assessment selected through CASS, the Assessing Officer is confined to the specific issues for which scrutiny was initiated. Enquiry into matters outside those issues is permissible only after conversion into complete scrutiny with the prescribed approval. Because the addition was made beyond the selected scrutiny scope and no valid conversion was shown, the Tribunal held that the assessment had travelled beyond jurisdiction and the addition was unsustainable. The assessee's appeal was allowed.
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