Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
After approval of the corporate insolvency resolution plan by the NCLT, an income-tax assessment founded on a section 148 notice issued only after that approval was impermissible. Applying the principle in Ghanashyam Mishra, the HC treated prior claims as extinguished once the resolution plan was approved, so a post-approval tax demand could not be sustained. The impugned assessment order was therefore unsustainable and was set aside.
After approval of the corporate insolvency resolution plan by the NCLT, an income-tax assessment founded on a section 148 notice issued only after that approval was impermissible. Applying the principle in Ghanashyam Mishra, the HC treated prior claims as extinguished once the resolution plan was approved, so a post-approval tax demand could not be sustained. The impugned assessment order was therefore unsustainable and was set aside.
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