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...
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
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