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...
Reassessment of an approved educational trust is unwarranted where, even after proposed disallowances, income applied to its objects remains above the 85% exemption threshold and no taxable income escapes assessment. The proviso to section 10(23C)(vi) permits accumulation of up to 15% of income, while section 152(2) permits reassessment proceedings to be dropped if the alleged escaped income does not reduce the assessed tax liability. Reopening and consequential reassessment were quashed. Revisionary power under section 264 may also modify, revoke or set aside an assessment made contrary to an interim court order, provided the resulting order is not prejudicial to the assessee; administrative system limitations do not excuse failure to remedy the breach.
Reassessment of an approved educational trust is unwarranted where, even after proposed disallowances, income applied to its objects remains above the 85% exemption threshold and no taxable income escapes assessment. The proviso to section 10(23C)(vi) permits accumulation of up to 15% of income, while section 152(2) permits reassessment proceedings to be dropped if the alleged escaped income does not reduce the assessed tax liability. Reopening and consequential reassessment were quashed. Revisionary power under section 264 may also modify, revoke or set aside an assessment made contrary to an interim court order, provided the resulting order is not prejudicial to the assessee; administrative system limitations do not excuse failure to remedy the breach.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
