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...
Validity of reopening of assessment - claim for deductions under section 80HHC and 80IA - the order of the A.O. stood merged with the order of the CIT(A) and had no existence of it’s own, and, as such, assessment could not be reopened in respect of the said item. - AT
Validity of reopening of assessment - claim for deductions under section 80HHC and 80IA - the order of the A.O. stood merged with the order of the CIT(A) and had no existence of it’s own, and, as such, assessment could not be reopened in respect of the said item. - AT
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