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...
Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
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