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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Under the substituted reassessment regime effective from 1 April 2021, issuance of a notice under section 148 and an order under section 148A(d) required prior approval from the specified authority in section 151. Where more than three years had elapsed from the end of the relevant assessment year, approval had to come from the higher authority identified in section 151(ii); approval by a Principal Commissioner was insufficient. The proviso allowing exclusion of time spent under section 148A(b), inserted by the Finance Act 2023, was treated as prospective. On that basis, the reopening was held invalid.
Under the substituted reassessment regime effective from 1 April 2021, issuance of a notice under section 148 and an order under section 148A(d) required prior approval from the specified authority in section 151. Where more than three years had elapsed from the end of the relevant assessment year, approval had to come from the higher authority identified in section 151(ii); approval by a Principal Commissioner was insufficient. The proviso allowing exclusion of time spent under section 148A(b), inserted by the Finance Act 2023, was treated as prospective. On that basis, the reopening was held invalid.
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