Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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