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...
Reopening of assessment - provision for damaged goods - full accounts, details and justifications for the claim was placed before AO in response to written query raised by the AO - in the final order of assessment, AO made no disallowance, it can hardly be stated that he did not form any opinion with respect to this claim of the assessee. - HC
Reopening of assessment - provision for damaged goods - full accounts, details and justifications for the claim was placed before AO in response to written query raised by the AO - in the final order of assessment, AO made no disallowance, it can hardly be stated that he did not form any opinion with respect to this claim of the assessee. - HC
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