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...
Draft assessment procedure under section 144C applies mandatorily where an assessee's non-resident status is accepted and the assessment falls within that provision. A final assessment made directly under section 143(3), without first forwarding a draft assessment order, is void. The appellate finding invalidating the assessment was sustained, and the Revenue's appeal was dismissed.
Draft assessment procedure under section 144C applies mandatorily where an assessee's non-resident status is accepted and the assessment falls within that provision. A final assessment made directly under section 143(3), without first forwarding a draft assessment order, is void. The appellate finding invalidating the assessment was sustained, and the Revenue's appeal was dismissed.
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