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...
Reassessment proceedings initiated by a notice under section 148 treat the return filed in response as a return under section 139. A notice under section 143(2) is required only where the Assessing Officer considers verification necessary or expedient; its absence does not by itself invalidate reassessment, particularly where the taxpayer participated in the proceedings and section 292BB applies. Additions made during reassessment must retain a direct nexus with the recorded reasons for reopening. Where a claimed business loss is set off against unreported non-compete income forming the basis for reopening, examination of that loss is connected to the recorded reasons; the substantive justification remains examinable in statutory appeal.
Reassessment proceedings initiated by a notice under section 148 treat the return filed in response as a return under section 139. A notice under section 143(2) is required only where the Assessing Officer considers verification necessary or expedient; its absence does not by itself invalidate reassessment, particularly where the taxpayer participated in the proceedings and section 292BB applies. Additions made during reassessment must retain a direct nexus with the recorded reasons for reopening. Where a claimed business loss is set off against unreported non-compete income forming the basis for reopening, examination of that loss is connected to the recorded reasons; the substantive justification remains examinable in statutory appeal.
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