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...
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
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