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...
Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.
Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.
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