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...
Unauthorised supervisory approval in a section 143(3) assessment following survey proceedings is not supported by statute, as section 133A does not require prior approval from a superior authority. The notes state that an Assessing Officer who consults or seeks such approval abdicates independent quasi-judicial discretion, vitiating the assessment. Applying this principle, the assessment was quashed and the remaining grounds were treated as academic.
Unauthorised supervisory approval in a section 143(3) assessment following survey proceedings is not supported by statute, as section 133A does not require prior approval from a superior authority. The notes state that an Assessing Officer who consults or seeks such approval abdicates independent quasi-judicial discretion, vitiating the assessment. Applying this principle, the assessment was quashed and the remaining grounds were treated as academic.
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