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 assessment completed u/s 144 - absence of notice - Since the notices were not received back “unserved” within thirty days of its issuance, there would be presumption under the law that notice had been duly served upon the assessee. The assessee received the Show Cause Notice u/s. 271(1)(b) dated 18.06.2008. Thus, the Assessment order u/s 144 is proper. - AT
Validity of assessment completed u/s 144 - absence of notice - Since the notices were not received back “unserved” within thirty days of its issuance, there would be presumption under the law that notice had been duly served upon the assessee. The assessee received the Show Cause Notice u/s. 271(1)(b) dated 18.06.2008. Thus, the Assessment order u/s 144 is proper. - AT
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