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 issued in the name of an amalgamated entity that has ceased to exist is an incurable jurisdictional defect and void from inception. Where the Assessing Officer knew of the amalgamation, the successor entity's participation cannot validate the assessment or cure it as a procedural irregularity under section 292B. Supreme Court precedent treats such assessment as a substantive illegality affecting jurisdiction. Consequently, the assessment against the erstwhile bank was quashed, and the merits of the additions were not examined.
Assessment issued in the name of an amalgamated entity that has ceased to exist is an incurable jurisdictional defect and void from inception. Where the Assessing Officer knew of the amalgamation, the successor entity's participation cannot validate the assessment or cure it as a procedural irregularity under section 292B. Supreme Court precedent treats such assessment as a substantive illegality affecting jurisdiction. Consequently, the assessment against the erstwhile bank was quashed, and the merits of the additions were not examined.
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