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...
Transfer of case u/s 147 - Deemed service of notice u/s 148 - AO never acquired jurisdiction over the assessee. Therefore, section 292BB does not come to the aid of the Department. Compliances would not bestow jurisdiction on the AO, once such jurisdiction never lay with the Assessing Officer to begin with - AT
Transfer of case u/s 147 - Deemed service of notice u/s 148 - AO never acquired jurisdiction over the assessee. Therefore, section 292BB does not come to the aid of the Department. Compliances would not bestow jurisdiction on the AO, once such jurisdiction never lay with the Assessing Officer to begin with - AT
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