Brand promotion expenditure requires an established associated-enterprise arrangement for transfer pricing, while management cross-charges must accoun...
Reassessment after the ordinary limitation period requires the escaped-income threshold and independent sanction, without expanding jurisdiction throu...
Transfer pricing comparability requires turnover and functional analysis, alongside rules on exempt-income disallowance and amalgamation goodwill depr...
Pre-approval income tax claims omitted from an approved resolution plan stand extinguished, and the plan binds government creditors. The Insolvency and Bankruptcy Code overrides inconsistent Income Tax Act provisions, preventing reassessment to pursue those claims. Refusal to waive statutory obligations in the plan approval order does not preserve an excluded claim. Reassessment provisions address income that has escaped assessment and cannot be used merely to collect evidence against former management or third parties. Lawful action against them may be pursued under separate statutory powers.
Pre-approval income tax claims omitted from an approved resolution plan stand extinguished, and the plan binds government creditors. The Insolvency and Bankruptcy Code overrides inconsistent Income Tax Act provisions, preventing reassessment to pursue those claims. Refusal to waive statutory obligations in the plan approval order does not preserve an excluded claim. Reassessment provisions address income that has escaped assessment and cannot be used merely to collect evidence against former management or third parties. Lawful action against them may be pursued under separate statutory powers.
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