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...
Revision u/s 263 by CIT(A) - it appears from record, the AO during the assessment proceedings has made enquiries on all these issues, though, it may not have been referred to in the assessment order. As it appears, in the garb of proceedings u/s 263 of the Act, the ld CIT in fact is undertaking an assessment proceeding himself - AO to re-consider the issues - AT
Revision u/s 263 by CIT(A) - it appears from record, the AO during the assessment proceedings has made enquiries on all these issues, though, it may not have been referred to in the assessment order. As it appears, in the garb of proceedings u/s 263 of the Act, the ld CIT in fact is undertaking an assessment proceeding himself - AO to re-consider the issues - AT
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