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...
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
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