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...
Assessment proceedings initiated and completed in the name of a person who had died before the second-round proceedings began lack legal validity. The legal heir's participation in appellate proceedings does not cure the foundational defect of assessing a non-existent deceased assessee. Consequently, the search assessment for the relevant assessment year was treated as void ab initio and quashed, while the remaining grounds were left open as academic.
Assessment proceedings initiated and completed in the name of a person who had died before the second-round proceedings began lack legal validity. The legal heir's participation in appellate proceedings does not cure the foundational defect of assessing a non-existent deceased assessee. Consequently, the search assessment for the relevant assessment year was treated as void ab initio and quashed, while the remaining grounds were left open as academic.
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