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...
Disallowance of deduction - AO should have made disallowance only while framing regular assessment or reassessment, which was made prior to resorting to this rectification. This disallowance cannot be made while acting u/s.154 of the Act reason being this is not a prima facie mistake it is a highly debatable issue - HC
Disallowance of deduction - AO should have made disallowance only while framing regular assessment or reassessment, which was made prior to resorting to this rectification. This disallowance cannot be made while acting u/s.154 of the Act reason being this is not a prima facie mistake it is a highly debatable issue - HC
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