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...
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
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