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...
Reassessment - though the amendment u/s 115JA / 115JB was made with retrospective effect, the critical date is the date on which the AO exercises jurisdiction u/s 148 - the subsequent amendment could not have been and is in fact not a ground on which the AO sought to reopen the assessment - HC
Reassessment - though the amendment u/s 115JA / 115JB was made with retrospective effect, the critical date is the date on which the AO exercises jurisdiction u/s 148 - the subsequent amendment could not have been and is in fact not a ground on which the AO sought to reopen the assessment - HC
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