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...
Extended period of limitation - period 9.7.2004 to 6.11.2005 - Board clarified vide its Circular on 17.10.2005 that software is 'goods', the show-cause notice in the present case was issued only on 2.1.2007 i.e. beyond the normal period of one year - demand set aside - AT
Extended period of limitation - period 9.7.2004 to 6.11.2005 - Board clarified vide its Circular on 17.10.2005 that software is 'goods', the show-cause notice in the present case was issued only on 2.1.2007 i.e. beyond the normal period of one year - demand set aside - AT
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