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 - return filed was processed u/s 143(1) - ITAT was right that the reopening was based merely on a change of opinion. Not only did he examine the records but came to the conclusion that "there was prima facie no evidence that the liabilities were not ascertained liabilities." - HC
Reopening of assessment - return filed was processed u/s 143(1) - ITAT was right that the reopening was based merely on a change of opinion. Not only did he examine the records but came to the conclusion that "there was prima facie no evidence that the liabilities were not ascertained liabilities." - HC
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