Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
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