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...
Unexplained foreign bank credits were remanded for fresh consideration because the assessee had not received an effective opportunity to submit supporting evidence on their source. The notes state that pending criminal financial-offence proceedings, custody, and detention under a look-out notice justified granting one further opportunity in the interests of justice. The appellate order was set aside, and the Commissioner (Appeals) was directed to reconsider the credits after providing a proper hearing and allowing supporting evidence to be furnished.
Unexplained foreign bank credits were remanded for fresh consideration because the assessee had not received an effective opportunity to submit supporting evidence on their source. The notes state that pending criminal financial-offence proceedings, custody, and detention under a look-out notice justified granting one further opportunity in the interests of justice. The appellate order was set aside, and the Commissioner (Appeals) was directed to reconsider the credits after providing a proper hearing and allowing supporting evidence to be furnished.
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